Operational guidance document on measuring personal consumer detriment : developed as part of the study on measuring consumer detriment in the European Union.
Date: 2017-07-04
Institutions: Consumers, Health, Agriculture and Food Executive Agency
Subjects: European Union, consumer protection, consumption, damage, market research, report, single market, user guide, welfare

Operational guidance 
document on measuring 
personal consumer detriment 

Developed as part of the Study on measuring consumer 
detriment in the European Union 

Written by Civic Consulting 
February 2017 

Justice and 
Consumers 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROPEAN COMMISSION 

Produced by Consumers, Health, Agriculture and Food Executive Agency (Chafea) on behalf of 

Directorate-General for Justice and Consumers 
Unit 0.3 — Economic analysis and evaluation 

Contact: Barbara Moench 

E-mail:  JUST-03@ec.europa.eu  

European Commission 
B-1049 Brussels 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROPEAN COMMISSION 

Operational guidance 
document on measuring 
personal consumer detriment  

Developed as part of the Study on measuring consumer 
detriment in the European Union  

Prepared by   Civic Consulting 
Sub-contractor  TNS Opinion (consumer survey implementation) 
Reported by   Dr Frank Alleweldt, Dr Senda Kara (directors) 

Nicholas McSpedden-Brown, Camille Salinier (project managers) 
Anthony Allen, Tanja Kimova (consumer survey, TNS opinion) 
Tommy Burke (expert group member) 
Phillip Evans (expert group member) 
Dr. Vaia Karapanou (expert group member) 
Dr. Pete Lunn (expert group member) 
Prof. Peter Lunt (expert group member) 
Prof. Peter Rott (expert group member) 
Support team   Agathe Osinski, Kris Best, Aysun Yahlier 
Date  

February 2017 

2017 

EN 

Directorate-General for Justice and Consumers 
EU Consumer Programme   

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study on measuring consumer detriment in the European Union 

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Study on measuring consumer detriment in the European Union 

Table of Contents 

0. Introduction and overview .......................................................................................... 7 

0.1. Aim of this guidance .................................................................................... 7 

0.2. Definition of personal consumer detriment...................................................... 7 

0.3. Key concepts concerning the measurement of personal consumer detriment....... 8 

0.4. Overview of steps to apply the methodology ................................................... 9 

Step 1 - Definition of the scope of the data collection ....................................................... 11 

1.1. Define the geographical scope of the assessment ........................................... 11 

1.2. Select the market(s) for assessment ............................................................. 11 

1.3. Determine the required sample size and survey mode .................................... 11 

1.4. Determine the additional data collection tool(s) to be used for triangulation 
of the results of the consumer survey, if necessary ............................................... 14 

1.5.  Consider  the  need  for  additional data  collection tool(s)  for  the  assessment 
among specific vulnerable consumer groups or in very low penetration markets ....... 15 

Step 2 - Consumer survey questionnaire ......................................................................... 17 

2.1. Screener questions ..................................................................................... 18 

2.2. Market module questions ............................................................................ 21 

2.3. Questions on socio-demographics and consumer expectations ......................... 44 

Step 3 - Assessment of detriment, triangulation and extrapolation ..................................... 48 

3.1. Measure the incidence of detriment .............................................................. 48 

3.2. Measure the magnitude of detriment ............................................................ 49 

3.3. Context to the detriment measured .............................................................. 55 

3.4. Triangulate results of consumer survey with other data sources, if relevant ....... 55 

3.5. Extrapolate results to country or for the entire EU, if relevant .......................... 56 

6 

 
 
 
 
 
Study on measuring consumer detriment in the European Union 

This document provides guidance for assessments of personal consumer detriment in 
consumer markets across the EU based on the work undertaken in the context of the 
Study on measuring consumer detriment in the European Union. 

0. Introduction and overview 

0.1. Aim of this guidance 

This  guidance  document  has  been  developed  with  the  aim  of  guiding  assessments  of 
personal  consumer  detriment,  whether  EU-wide  in-depth  consumer  market  studies 
focusing  on  a  single  market  or  cross-market  assessments,  based  on  the  work 
undertaken  in  the  context  of  the  Study  on  measuring  consumer  detriment  in  the 
European  Union  (hereafter  also  referred  to  as  'the  consumer  detriment  study').1  It 
explains  the  methodological  steps  and  market-specific  adaptations  to  employ  for  the 
development  of  the  consumer  survey  questionnaire  and  assessment  of  personal 
consumer  detriment  based  on  the  data  collected,  and  provides  advice  regarding  the 
use of complementary tools and approaches for the triangulation and extrapolation of 
results. 

0.2. Definition of personal consumer detriment 

Consumer  detriment  arises  when  market  outcomes  fall  short  of  their  potential, 
resulting  in  welfare  losses  for  consumers.  A  study  commissioned  by  the  European 
Commission  on  consumer  detriment  in  20072  differentiated  between  two  forms  of 
consumer detriment: ‘structural detriment’ and ‘personal detriment’: 

•  Structural detriment refers to the loss of consumer welfare in the aggregate 
due to market failure or regulatory failure, as compared to well-functioning 
markets; 

•  Personal  detriment  refers  to  the  difference  between  the  value  that 
consumers reasonably expected to get from a good or service and the value 
that  they  actually  get  from  it,  relating  to  problems  experienced  by 
consumers post-purchase. 

A key difference between structural and personal consumer detriment is that while the 
latter affects an individual in a specific transaction, the former arises from a structural 
problem that affects an entire market or sector. The incidence of structural consumer 
detriment  is  therefore  largely  independent  of  an  individual  consumer's  decision-
making  ability,  behavioural  bias,  expectations,  etc.  Indeed,  it  is  likely  to  affect  the 
majority of consumers in that market or sector. 

The  2007  detriment  study  explained  that  it  applied  the  term  ‘personal’  because  it 
relates  to  the  personal  experience  of  those  consumers  for  whom  something  goes 
wrong.  It  is  a  topic  that  is  regularly  addressed  in  in-depth  market  studies  and  the 
European  Commission’s  Consumer  Scoreboards,  it  is  a  pivotal  element  for  setting 
priorities  in  sectoral  or  competition  policies,  and  is  in  general  the  focus  of  many 
consumer protection activities and much legislation affecting consumers. Accordingly, 
the methodology developed in the context of the consumer detriment study (hereafter 
referred  to  as  'the  methodology')  focuses  on  the  assessment  of  personal  consumer 
detriment. 

1 Civic Consulting, Study on measuring consumer detriment in the European Union, 2016. 

2  Europe  Economics,  An  Analysis  of  the  Issue  of  Consumer  Detriment  and  the  Most  Appropriate 
Methodologies to Estimate It, 2007. 

7 

 
 
                                                 
Study on measuring consumer detriment in the European Union 

Furthermore,  the  OECD  Consumer  Policy  Toolkit  (2010)3  and  previous  survey-based 
assessments  of  consumer  detriment4  have  made  the  distinction  between  detriment 
that  consumers  are  aware  of  –  termed  revealed  detriment  –  and  detriment  which 
consumers  are  unaware  of  –  termed  unrevealed  or  hidden  detriment.  Research 
conducted  in  the  consumer  detriment  study  concluded  that  hidden  detriment  is 
primarily captured with the concept of structural detriment, because it tends to relate 
to  problems  affecting  consumers  in  the  aggregate  through  market  or  regulatory 
failures.  Moreover,  as  problems  reported  by  consumers  are  the  focus  of  the 
assessment of personal consumer detriment, a consumer survey is used as part of the 
methodology,  which  thereby  focuses  on  the  assessment  of  revealed  personal 
consumer detriment. 

Hence,  the  following  is  the  definition  of  revealed  personal  consumer  detriment 
developed in order to guide the application of the methodology: 

Revealed personal consumer detriment is defined as negative outcomes for individual consumers 
that they become aware of following the purchase or use of a good or service, measured relative to 
what would reasonably have been expected given the type of transaction. 

Both the structural and hidden forms of detriment are important to consider in a policy 
perspective  in  addition  to  revealed  personal  consumer  detriment.  However,  for 
assessing structural and/or hidden detriment, other methodological approaches will be 
needed. For structural detriment, this could involve sector inquiries as well as specific 
methods  relating  to  assessing  market  power  such  as  modelling.5  For  unrevealed 
detriment  relating  to  welfare  losses  that  result  for  example  from  not  knowing  about 
the possibility to switch to another provider offering a lower-priced tariff with the same 
properties,  or  from  having  to  pay  a  higher  price  for  goods  purchased  online  due  to 
websites’  consumer  profiling,  this  could  involve  market  research  on  available 
tariffs/price  variations  according  to  different  profiles,  possibly  complemented  by 
behavioural research concerning switching behaviour of consumers. 

0.3.  Key  concepts  concerning  the  measurement  of  personal  consumer 
detriment 

Two  main  aspects  of  revealed  personal  consumer  detriment  need  to  be  measured  as 
part of an assessment of revealed personal consumer detriment: the incidence and the 
magnitude of detriment.  

In a survey sample, the incidence refers to the proportion of respondents who experienced a problem 
in a given time period as a percentage of the total sample surveyed.  

Measuring  incidence  of  detriment  therefore  equates  to  providing  an  estimate  of  the 
occurrence of problems in a given market. 

3 Available at http://dx.doi.org/10.1787/9789264079663-en  

4  Consumer  Affairs  Victoria  (2006);  Office  of  Fair  Trading  (2008);  London  Economics  (2009);  UK 
Department  for  Business  Innovation  and  Skills/TNS  (2014);  Irish  Competition  and  Consumer  Protection 
Commission /Ipsos MORI (2014). 

5  Examples  of  methodological  approaches  to  assess  structural  detriment  outlined  in  the  2007  detriment 
study  include  analysing  data  relating  to  market  power  such  as  price  mark-ups  and  concentration  indices, 
theoretical market models, or other modelling involving econometrics or simulations. Moreover, Commission 
policies addressing structural detriment include e.g. competition policies (such as antitrust policy) or internal 
market policies aimed at reducing barriers to cross-border trade. 

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Study on measuring consumer detriment in the European Union 

In a survey sample, the average magnitude of personal consumer detriment refers to the extent or 
the level to which respondents who experienced a problem suffered detriment on average.6  

Measuring  magnitude  of  detriment  therefore  equates  to  providing  an  estimate  of 
severity  or  gravity  of  problems  in  a  given  market.  Magnitude  of  detriment  can  be 
measured in terms of several dimensions: financial detriment, time loss, psychological 
detriment, or adverse effects on health. 

•  Financial  detriment  can  be  defined  as  the  monetary  costs  and  losses 
incurred by the consumer as a result of a problem with a good or service. It 
refers both to the financial losses resulting directly from the problem as well 
as  costs  incurred  from  trying  to  sort  out  the  problem.  Two  estimates, 
corresponding  to  two  different  stages,  can  be  distinguished:  pre-redress 
financial  detriment  (i.e.  prior  to  receiving  any  substantial  redress,  e.g.  in 
the  form  of  monetary  reimbursement  or  compensation,  or  replacing  the 
good  or  service,  etc.)  and  post-redress  financial  detriment  (i.e.  financial 
detriment net of any redress received). 

•  Time loss refers to the total amount of time a consumer has spent either as 
direct  result  of  a  problem,  e.g.  in  cases  of  delay,  or  from  trying  to  sort  a 
problem  out,  e.g.  by  travelling  to  the  trader’s  premises.  Time  loss  is  a 
critical dimension of personal detriment, as many problems may be of little 
direct  financial  consequence  to  consumers  but  nonetheless  a  significant 
cause of detriment when considering the value of the time loss. 

•  Psychological  detriment  refers  to  the  emotional  stress  experienced  by 
consumers  as  a  result  of  problems,  in  terms  of  frustration,  anxiety,  anger 
or  offence,  or  disappointment.  Similarly  to  time  loss,  psychological 
detriment is a critical dimension of personal detriment, which is often likely 
to go hand in hand with substantial time loss. 

For  a  comprehensive  assessment  of  magnitude  of  detriment  in  most  consumer 
markets,  financial  detriment,  time  loss  and  psychological  detriment  should  be 
assessed. In addition, adverse health effects (e.g. injuries) could be considered in the 
context of markets for which these dimensions would be specifically relevant.7 

0.4. Overview of steps to apply the methodology 

The  implementation  of  the  methodology  follows  a  series  of  steps,  which  form  part  of 
three  main  phases  –  the  definition  of  the  scope  of  the  data  collection,  adaptation  of 
the  consumer  survey  questionnaire  to  the  selected  markets,  and  implementation  of 
the assessment, triangulation and extrapolation – as shown in the diagram below. 

6  Personal  consumer  detriment  at  the  market  level  (measured  by  combining  incidence  and  magnitude)  is 
discussed as part of the extrapolation in Step 3. 

7 Examples of relevant questions for assessing adverse health effects are provided in Europe Economics, An 
Analysis  of  the  Issue  of  Consumer  Detriment  and  the  Most  Appropriate  Methodologies  to  Estimate  It, 
London,  2007  and  Ipsos  MRBI  /  Competition  and  Consumer  Protection  Commission,  Consumer  Detriment 
Survey 2014, 2014 respectively. 

9 

 
 
 
                                                 
Study on measuring consumer detriment in the European Union 

Figure 1: Overview of steps to apply the methodology 

Definition of the scope of 
the data collection 

Adaptation of consumer 
survey questionnaire to 
the selected markets 

Implementation of the 
assessment, triangulation 
and extrapolation 

•Define the geographical 
scope of the assessment 
•Select the market(s) for 
assessment 
•Determine the required 
sample size and survey mode 
•Determine the additional 
data collection tool(s) to be 
used for triangulation of the 
results of the consumer 
survey, if necessary 
•Consider the need for 
additional data collection 
tool(s) for assessing personal 
consumer detriment among 
specific vulnerable consumer 
groups or in very low 
penetration markets 

•Adapt screener questions to 
type of assessment 
•Identify relevant products for 
markets selected and adapt 
related survey questions 
•Identify relevant problem 
types for markets selected 
and adapt related survey 
questions 
•Establish dimensions of 
personal consumer 
detriment to measure and 
adapt related questions 
•Establish additional 
contextual information to 
assess and adapt related 
questions 
•Adapt questions on socio-
demographics and  consumer 
expectations  

•Measure the incidence of 
detriment based on the 
consumer survey data 
•Measure the magnitude of 
detriment based on the 
consumer survey data 
•Provide context to the 
detriment measured, if 
relevant 
•Triangulate results of 
consumer survey with other 
data sources, if relevant 
•Extrapolate results to EU 
level, if relevant 

In the following we describe each of these steps in detail. 

10 

 
 
 
 
 
Study on measuring consumer detriment in the European Union 

Step 1 - Definition of the scope of the data collection 

1.1. Define the geographical scope of the assessment 

The first step of the assessment is to define its geographical scope. If the assessment 
is aimed at extrapolating the results of a sample of countries to the EU level, criteria 
for  the  selection  of  countries  to  be  surveyed  should  be  established.  These  could 
include  the  EU  region  (Northern,  Western,  Southern  or  Eastern  Europe),  market  size 
level  of  consumer  protection  (using  e.g. 
(e.g.  population  size),  perceived 
Eurobarometer  survey  data),  and  incidence  of  consumer  detriment  (using  e.g.  data 
from Eurobarometer surveys or the European Commission's Market Monitoring Survey 
(MMS),8 see below). 

1.2. Select the market(s) for assessment 

The  number  and  nature  of  consumer  goods  and  services  markets  selected  for 
assessment  have  important  implications  for  the  methodological  approach.  For 
example,  assessing  several  markets  (i.e.  a  ‘cross-market  assessment’)  implies 
designing ‘screener’ questions applicable across all these markets (see Step 2.1 below 
for more details).  

1.3. Determine the required sample size and survey mode 

The  assessment  of  the  incidence  and  magnitude  of  personal  consumer  detriment  is 
based  on  a  consumer  survey  conducted  in  the country  or  countries  to  be  covered  by 
the  research.  The  survey  targets  the  overall  population  and  does  not  apply  any  pre-
screening of respondents.9 When applying the methodology, the sample size and the 
survey mode have to be determined. The sample size depends, among others, on the 
expected  incidence  rate  of  problems  experienced  by  consumers  in  the  selected 
markets(s),  as  a  certain  minimum  number  of  respondents  with  problems  has  to  be 
identified to determine the average magnitude of detriment.10  

The  expected  incidence  rate  of  problems  in  the  selected  market(s)  can  be  estimated 
using  data  from  the  European  Commission’s  Consumer  Market  Scoreboard/Market 
Monitoring Survey (MMS). This is done by multiplying the MMS problem rate – i.e. the 
percentage  of  respondents  who  reported  experiencing  a  problem  in  a  market,  as  a 
proportion  of  those  who  purchased/paid  for  a  good  or  service  in  the  market  in 
question  –  by  the  market  penetration  rate,  i.e.  the  percentage  of  respondents  who 

8  European  Commission,  Monitoring  Consumer  Markets 
http://ec.europa.eu/consumers/consumer_evidence/consumer_scoreboards/ 
market_monitoring/index_en.htm  

in  the  European  Union.  Available  at: 

9 The absence of any pre-screening allows for establishing the incidence rate of problems experienced in the 
population directly for multiple markets at the same time (cross-market assessment). In contrast, a study 
focusing  on  one  single  market  will  typically  pre-screen  potential  respondents  to  identify  consumers  that 
purchased/paid  for  the  selected  good  or  service,  and  ask  at  a  later  stage  whether  or  not  a  problem  was 
experienced with this good or service. In this case, the incidence rate of problems with the good or service 
in the population is not directly established and has to be calculated through applying an appropriate market 
penetration rate (e.g. measured during the pre-screening of respondents or through the Market Monitoring 
Survey). 

10  For  example,  regarding  the  surveys  conducted  for  testing  the  methodology  a  base  size  of  50  or  more 
respondents who experienced a problem per country and market  were considered appropriate to  calculate 
average levels of detriment. Where base sizes were below 50 respondents, average levels of detriment were 
provided, with a note that these results are to be interpreted with caution. Base sizes below 30 respondents 
were considered insufficient for calculation of averages. 

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Study on measuring consumer detriment in the European Union 

purchased/paid for a good or service in the market in question in the reference period 
as a proportion of those who were sampled. 11 

The  estimated  incidence  rate  of  problems  for  that  market  in  the  population  can  then 
be  used  to  estimate  the  required  sample  size  for  the  survey,  based  on  the  target 
number  of  respondents  who  experienced  a  problem,  which  has  to  be  defined  in  the 
design  phase  of  the  assessment.  The  lower  the  expected  incidence  rate  of  problems 
and  the  bigger  the  targeted  number  of  respondents  who  experienced  a  problem,  the 
larger  the  size  of  the  survey  sample  that  is  needed.  This  is  illustrated  in  the  table 
below: 

Table 1: Required sample sizes to reach target number of respondents  

Expected incidence 
rate of problems 

Target number of respondents who experienced a problem 

1% 

2% 

3% 

4% 

5% 

7% 

10% 

15% 

20% 

30 

3000 

1500 

1000 

750 

600 

450 

300 

200 

150 

50 

5000 

2500 

1700 

1250 

1000 

750 

500 

350 

250 

70 

7000 

3500 

2350 

1750 

1400 

1000 

700 

500 

350 

Source: Civic Consulting. Note: Required sample sizes rounded to the next higher multiple of 50. 

For example, if a survey aims at identifying at least 50 respondents who experienced a 
problem  in  a  given  market  and  country  and  the  expected  incidence  rate  calculated 
based  on  MMS  data  for  this  market  is  15%,  a  minimum  of  about  350  respondents 
would  need  to  be  sampled.  In  contrast,  considering  the  example  of  the  market  for 
large household appliances, which has both a substantially lower penetration rate and 
a  lower  problem  rate,  leading  to  an  expected  incidence  rate  of  problems  in  the 
population of 4%, a minimum of around 1250 respondents would need to be sampled 
to identify at least 50 respondents who experienced a problem.  

The  table  also  illustrates  why  markets  in  which  consumers  particularly  rarely  make 
transactions – defined as markets with very low penetration rates12 – are likely to be 
unsuitable for a survey-based assessment. The resulting incidence of problems in the 
population is very low, and even with large sample sizes for the survey (or extensive 
pre-screening  in  case  of  single  market  assessments),  it  is  unlikely  that  a  sufficient 
number  of  respondents  who  have  experienced  problems  could  be  identified  in  these 
markets  to  allow  for  an  analysis  of  detriment.  Therefore  other,  complementary  tools 
are likely to be required (see Step 1.5 for further details). 

11  The  specific  questions  applied  and  sample  size  used  as  a  basis  for  estimating  the  problem  rate  in  the 
Market  Monitoring  Survey  should  be  taken  into  account  when  interpreting  the  expected  incidence  rate,  as 
the  screener  questions  proposed  in  this  methodology  used  as  a  basis  for  estimating  incidence  differ  (see 
Step 2 for an overview of the questionnaire). 

12 Markets with very low penetration rates, such as online gambling, can be identified using data from the 
European Commission’s Market Monitoring Survey. 

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Study on measuring consumer detriment in the European Union 

Other  considerations that affect the needed sample sizes are the targeted confidence 
level,  the  acceptable  margin  of  error,  and  the  standard  deviation,  if  observed  in 
previous assessments of detriment. As a rule, higher confidence levels, lower margins 
of error and higher standard deviations (e.g. of reported financial detriment) in target 
markets all require a larger sample size of respondents who experienced problems. 13  

Another choice to be made in the preparatory  phase  of the assessment concerns the 
survey  mode.  For  example,  for  developing  the  methodology  in  the  consumer 
detriment  study,  two  survey  modes  were  used  –  online  panels  and  face-to-face 
omnibus surveys (with a sample size of 2000 for both modes in each of the surveyed 
countries).  After  controlling  for  the  different  socio-demographic  composition  of  the 
survey  samples,  the  choice  of  survey  mode  was  found  to  have  a  highly  statistically 
significant  effect  on  the  likelihood  of  reporting  problems  in  the  markets  under  study, 
with  online  survey  respondents  being  roughly  three  times  more  likely  than  face-to-
face  respondents  to  report  a  problem.  The  higher  incidence  rates  obtained  in  the 
online mode can affect the required sample size considerably.14 

All survey modes, including the online and face-to-face modes used for developing the 
methodology but also the telephone mode used in the MMS, have certain advantages 
but  also  potential  sources  of  bias,  which  may  differ  between  modes.  For  example, 
online  surveys  provide  anonymity  and  each  respondent  can  choose  the  appropriate 
time  frame  for  responding,  but  these  surveys  are  also  more  susceptible  to  self-
selection  bias,  since  respondents  consciously  choose  whether  or  not  to  participate  in 
an online panel. While the quota based sampling approach that is applied in the online 
mode and the subsequent weighting procedure serves to reduce the self-selection bias 
of online panels by matching the composition of the respondents from the panel with 
the  composition  of  the  population,  the  non-online  population  is  by  definition  not 
represented in this type of panel. In contrast, both face-to-face and telephone surveys 
are  based  on  a  stratified  probability  sampling  approach,  which  is  designed  to  be 
representative  for  the  overall  population,  but  they  also  place  greater  time  and  social 
pressure  on  respondents  (due  to  the  presence  of  an  interviewer),  which  has  been 
shown  to  produce  less  accurate  or  less  detailed  responses  in  some  circumstances. 15 
Also,  in  both  face-to-face  and  phone  surveys  the  number  of  targeted  consumers  not 
willing  to  participate  in  the  survey  may  be  substantial,  introducing  a  certain  level  of 
self-selection bias as well.  

While face-to face surveys with a probability sampling design are generally considered 
to be the most robust mode and therefore the gold standard in market research, the 
mentioned  potential  biases  in  all  modes  do  not  make  it  possible  to  state  definitively 
and  for  all  situations  the  degree  to  which  results  obtained  in  one  mode  are  more 
accurate than results obtained in another.16  

Such 

13 
https://www.qualtrics.com/blog/determining-sample-size/ for an overview. 

considerations 

statistical 

sampling 

apply 

to 

in 

general. 

See 

e.g. 

14 For example, assuming a targeted number of 50 respondents who experienced a problem per market and 
country, with a sample size of 2000, the face-to face-survey conducted in the consumer detriment study for 
testing the methodology did not reach this target number of respondents (or base size) in more than a third 
of the market/country combinations. In contrast, the online survey with an identical sample size reached the 
base size of 50 in all markets/countries. Even if the sample size for the online survey had been 1000, the 
survey would have obtained the base size of 50 or more in most market/country combinations. 

15 See for example Duffy et al (2005), “Comparing data from online and face-to-face surveys”, available at 
https://www.ipsos-mori.com/Assets/Docs/Archive/Publications/comparing-data.pdf  

16  Further  research  into  the  relative  accuracy  of  one  survey  mode  over  another  could  be  conducted  e.g. 
through  experiments  involving  randomised  controlled  trials  (RCTs)  designed  specifically  to  test  the  mode 
effect. 

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Taking note of the strength of the mode effect described above (which cannot be explained through 
socio-demographic differences in sample composition according to the results of the regression 
analysis), it is recommended that for estimating incidence of consumer problems in a given market, 
data from one survey mode be complemented with data from other survey modes, if available, to 
establish ranges of estimates.  

This  could  be  done,  for  example,  by  complementing  the  incidence  estimate  from  an 
online survey – which is the survey mode implying the lowest costs – with the results 
of an omnibus face-to-face survey (as was done in the consumer detriment study) or 
with  an  estimate  based  on  existing  data  from  a  Eurobarometer  survey  (often  a  face-
to-face  survey)  or  the  MMS  (which  is  based  on  a  phone  survey).17  Estimates  of 
incidence of problems should be presented as ranges of results from different modes, 
where possible, rather than relying on point estimates from a single mode.  

In contrast, the broadly similar results for the magnitude of financial detriment across the two 
modes tested for the development of the methodology would imply that it is adequate to estimate 
magnitude of detriment based on results from only one survey mode. 

1.4.  Determine  the  additional  data  collection  tool(s)  to  be  used  for 
triangulation of the results of the consumer survey, if necessary 

The European Commission Better Regulation Toolbox (Tool 2) emphasises the benefit 
of  triangulation,  in  the  sense  that  it  can  facilitate  validation  of  data  through  cross 
verification  from  two  or  more  sources  by  "the  application  and  combination  of  several 
research  methodologies  in  the  study  of  the  same  phenomenon",  as  it  "enhances 
confidence  in  results  if  different  methods  lead  to  the  same  result".  Accordingly, 
beyond the assessment of personal consumer detriment itself, the extent to which the 
findings  of  the  assessment  will  be  triangulated  with  other  relevant  data  has  to  be 
defined. Possible sources of data for triangulation include: 

•  Review  of  literature  and  previous  surveys  and  reports  (including  the 
European  Commission’s  Consumer  Market  Scoreboard/Market  Monitoring 
Survey, market studies and Eurobarometers); 

• 

Interviews  with  experts,  consumer  organisations  and  complaint  handling 
bodies; 

•  Data on consumer complaints; 

•  Mystery shopping exercises; 

•  Court awards for cases of harm or injury, in cases where the measurement 
of detriment from adverse effects on health is included in the assessment. 

A review of literature and previous reports and surveys as well as selected interviews 
is  an  important  source  of  data  to  consider,  given  that  it  is  also  required  for  refining 
problem categories and other elements of the questionnaire (see below for details).18  

17  In  the  latter  case,  results  will  have  to  be  interpreted  with  care,  as  the  wording  of  questions  regarding 
problems consumers have experienced with goods or services will likely differ from the wording developed in 
this methodology (see also Annex I of the consumer detriment study).  

18 Annex XVIII of the consumer detriment study presents a list of relevant literature. 

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Data  on  consumer  complaints  across  EU  Member  States  is  becoming  increasingly 
harmonised  and  centrally  available  thanks  to  the  development  of  the  European 
Commission  harmonised  complaints  database.19  Complaints  data  also  span  the  same 
range of potential types of problems as those that are relevant for a consumer survey. 
In this regard, EU consumer complaints data allow for comprehensive triangulation of 
data across the range of problem types reported in the consumer survey. Nonetheless, 
gaps in the database, e.g. concerning specific countries, markets or time periods, may 
call  for  a  survey  of  complaint  handling  bodies  to  complement  the  data  from  the 
harmonised database. 

Another  potential  complementary  tool  to  obtain  data  for  triangulation  is  a  mystery 
shopping  exercise.  In  order  to  cover  a  significant  share  of  traders  active  in  the 
markets and  countries  selected for analysis, a web check based on the review  of the 
websites of traders can be considered. Such an exercise allows for the identification of 
issues  related  to  selected  unfair  commercial  practices  and  to  the  provision  of  pre-
contractual  information  that  potentially  could  cause  consumer  detriment,  and  can 
therefore  be  used  to  triangulate  consumer  survey  results  for  corresponding  problem 
types.  However,  due  to  its  specific  focus,  its  use  should  primarily  be  considered  for 
markets  in  which  consumer  problems  related  to  advertising  and  provision  of  pre-
contractual information are a concern, e.g. for mobile telephone services. 20 

Further details on the approach to triangulation are provided below (Step 3.4). 

1.5. Consider the need for additional data collection tool(s) for the assessment 
among  specific  vulnerable  consumer  groups  or  in  very  low  penetration 
markets 

Assuming that the number of survey respondents that have experienced a problem is 
sufficiently  large,  it  will  be  possible  to  analyse  and  compare  the  incidence  and 
magnitude  of  detriment  of  sub-samples  of  respondents,  including  those  presenting 
factors associated with/drivers of consumer vulnerability21 (defined in the following as 
‘vulnerable consumer groups’) on the basis of targeted questions. See Step 2.3 for an 
overview  of  survey  questions  relating  to  factors/drivers  of  consumer  vulnerability  in 
the questionnaire. For instance, a question on the frequency of internet use was added 
to the face-to-face survey questionnaire in the consumer detriment study, as a useful 
proxy for identifying vulnerable consumer groups. 

However,  a  survey  may  not  always  deliver  a  sufficient  number  of  respondents  for  an 
assessment of the detriment among specific types  of  vulnerable consumers, as some 
relevant groups are less likely to be captured by a survey even with large sample sizes 
(such as migrants with language difficulties or such as consumers with less access to 
the internet, as shown  in the consumer detriment study  results). Moreover, a survey 

19  The  European  Commission  harmonised  consumer  complaints  database  can  be  accessed  here: 
http://ec.europa.eu/consumers/consumer_evidence/data_consumer_complaints/index_en.htm. 

20 Please see the results of the triangulation of consumer survey results in the main report of the study on 
measuring consumer detriment in the European Union for an illustration. 

21 Consumer vulnerability is a multi-faceted and complex concept, as highlighted in European Commission, 
Consumer  vulnerability  across  key  markets  in  the  European  Union,  2016.  The  study  characteristics 
vulnerability  according  to  the  following  dimensions:  heightened  risk  of  negative  outcomes  or  impacts  on 
well-being; having characteristics that limit ability to maximise well-being; having difficulty in obtaining or 
assimilating  information;  inability  or  failure  to  buy,  choose  or  access  suitable  products;  and,  higher 
susceptibility  to  marketing  practices,  creating  imbalances  in  market  interactions.  The  study  identified 
several  factors  associated  with/drivers  of  vulnerability  as  defined  by  these  dimensions,  including  personal 
and demographic characteristics (e.g. old age, low education), situational drivers of vulnerability (e.g. long-
term  unemployment,  or  difficulty  to  make  ends  meet),  behavioural  drivers  of  vulnerability  (e.g.  very  low 
willingness to take risks), or access drivers of vulnerability (e.g. infrequent internet use). 

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is  typically  not  well  suited  for  providing  details  on  the  reasons  for  which  vulnerable 
consumers  suffer  from  detriment,  which  are  also  important  from  a  policymaking 
perspective. 

Hence, for an in-depth assessment of detriment among vulnerable consumers, a first 
step  could  be  contacting  relevant  consumer  organisations  or  other  organisations 
representing  the  groups  of  interest  to  collect  information  and  potentially  identify 
vulnerable consumers in specific markets for targeted interviews. Qualitative research 
targeting  experts  relevant  for  those  vulnerable  groups  and/or  the  vulnerable 
consumers themselves can provide in-depth information on consumers’ experiences. 22 

Moreover, while markets with a relatively lower penetration rate can  still be targeted 
in  surveys,  markets  with  exceptionally  low  penetration  rates,  e.g.  online  gambling, 
would  pose  challenges  for  an  accurate  assessment  of  detriment,  since  the  costs 
needed  to  achieve  a  sufficiently  large  sample  size  of  respondents  having  suffered 
detriment  are  very  high.  In  an  assessment  focusing  on  one  market  (i.e.  a  single-
market  assessment),  options  include  the  use  of  a  larger  reference  period  for  such 
markets  (e.g.  asking  respondents  to  recall  problems  2  or  3  years  ago),  or  pre-
screening the  sample. However,  if  this is not  feasible,  additional  tools are  necessary. 
This could involve contacting relevant stakeholders such as complaint handling bodies 
and relevant consumer groups to collect targeted information and identify consumers 
that  regularly  make  purchases  in  those  markets.  Similarly  to  the  approach  described 
for  vulnerable  consumer  groups,  additional  qualitative  research  could  be  envisaged, 
including through interviews and focus groups with consumers who have experienced 
a problem in the selected market(s).  

Such additional pre-screening and/or tools would also be necessary for an assessment 
focusing on specific consumer groups, defined on the basis of personal characteristics, 
e.g.  older age groups,  or  consumer experience,  e.g.  consumers who  took a trader to 
court or to an alternative dispute resolution body. 

22  Common  methods  of  qualitative  research  include  focus  groups  or  individual  unstructured  or  semi-
structured  interviews.  The  sample  size  is  generally  small,  and  respondents  are  selected  to  fulfil  a  given 
quota – e.g. a particular sub-set of consumers such as retired or old age consumers. Qualitative research is 
used  to  gain  an  understanding  of  underlying  reasons,  motivations  or  opinions,  and  may  provide  deeper 
insights into the detriment or help develop ideas or hypotheses for a potential quantitative survey. 

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Step 2 - Consumer survey questionnaire  

The  consumer  survey  questionnaire  implemented  in  the  consumer  detriment  study  is 
in Annex III of the main report. 

The  consumer  survey  questionnaire  is  composed  of  three  main  components:  the 
screener, the market module(s) and the socio-demographic questions, potentially also 
including  a  control  question  on  consumer  expectations.23  The  questions  can  be  sub-
divided into three broad categories: those needed for measuring incidence of personal 
consumer  detriment,  or  for  measuring  magnitude  of  personal  consumer  detriment, 
and those that provide additional ‘contextual’ information for the assessment.  

The diagram below provides a graphical overview of the questionnaire.  

23  A  control  question  on  expectations  was  included  in  the  survey  implemented  in  the  consumer  detriment 
study,  to  control  for  the  effect  of  consumer  expectations  on  the  magnitude  of  the  financial  detriment 
experienced.  Results  showed  that  consumer  expectations  do  not  have  a  significant  effect  on  financial 
detriment  in  the  markets  assessed  in  the  study.  Nevertheless,  including  a  question  on  consumer 
expectations in future assessments could be considered on a case-by-case basis. 

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Figure 2: Overview of questionnaire  

Initial sociodemographic questions 

•Asked to whole sample 
•Provide contextual information on the respondent (age, region, 
gender) 

Screener 

•Asked to whole sample 
•Determines whether respondent experienced problem(s) in the 
sample markets, and thereby establishes incidence of detriment 
across the sample markets 
•Determines in which market respondent experienced most 
serious problem, to be explored in market module 

Market module no.1 

•Asked to sub-sample experiencing problems 
•Focuses on most serious problem 
•Establishes magnitude of detriment for market in question, in 
terms of financial detriment, time loss and psychological 
detriment 
•Provides contextual information on the detriment 

Market module no.2 

•Asked to sub-sample experiencing problems 
•Focuses on second most serious problem, if applicable 
•Contributes to establishing magnitude of detriment and providing 
related contextual information 

Final socio-demographic/control questions 

•Can be asked either to the whole sample or only to those who 
experienced problems, depending on needs 
•Provide contextual information on the respondent (such as 
education level, financial situation, and expectations concerning 
goods and services) 

Source: Civic Consulting. Note: The order of the questions presented in the diagram is based on the online survey 
questionnaire that was implemented in the consumer detriment study and where gender, age and region were used to 
set quotas and other standard socio-demographic and control questions were asked at the end and posed in standard 
order. 

The  following  sub-sections  describe  each  of  the  components  of  the  questionnaire  in 
more detail and provide guidance as to how to adapt these components to the needs 
of the assessment. 

2.1. Screener questions  

The screener refers to the set of questions asked of the entire sample aimed at both jogging the 
respondent’s memory into remembering problems relevant for the selected market(s) and 
establishing in which of the market(s) the respondent experienced problem(s) and in which market 
his/her most serious problem was experienced.  

The  screener  questions  are  therefore  instrumental  for  assessing  the  incidence  of 
personal consumer detriment in the selected markets. The screener also clarifies that 
respondents  should  only  report  problems  for  which  they  had  a  legitimate  cause  for 

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complaint. Referring only to those problems that can be considered a ‘legitimate cause 
for  complaint’ creates a benchmark  for the concept of reasonable expectations in the 
definition of personal consumer detriment outlined above.  

The table below provides an overview of the screener questions developed and applied 
in the consumer detriment study. 

Table 2: Overview of screener questions 

Q. 

Question topic 

Incidence 
measurement 

Magnitude 
measurement 

S1 

Examples of types of consumer problems 

S2A/B 

Markets in which problems experienced 

S3 

Market in which most serious problem 
experienced 

√ 

√ 

Source: Civic Consulting. Screener questions are asked to the entire sample. 

√ 

The  adaptation  of  the  screener  questions  depends  on  whether  a  cross-market 
assessment (involving multiple markets) or a single-market assessment is conducted. 
The table below outlines the approach for adapting the screener in the case of a cross-
market  assessment.  For  a  single-market  assessment,  a  similar  approach  can  be 
applied, although, only one question is likely to be necessary (S1). 

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Table 3: Screener questions for cross-market assessment –S1 to S3 

Q. 

Cross-market assessment, question and answer items 

S1 -Examples of types 
of consumer problems 

Question: Does looking at the list below remind you of any problems experienced 
in the last 12 months for which you feel you had a legitimate cause for complaint? 
- Faulty goods or services 
- Late or no delivery 
- Billing issues 
- Poor customer service 
- Misleading information or advertising 
- Guarantee or warranty not honoured 
- No or inadequate compensation offered when something went wrong 
- Problems cancelling a contract 

Answer items: 
(1) Yes 
(2) No 

S2A - Markets in 
which problems 
experienced* 
(If ‘No’ in S1) 

Question: To help remind you about any problems you may have experienced, the 
list below outlines different types of goods or services. 
Please indicate all goods or services you have experienced a problem with in the 
last 12 months, either with the goods or services or the seller/provider.  
It doesn't matter whether or not you complained about the problem, but it must 
be something for which you had a legitimate cause for complaint. 

Answer items:  
List of markets assessed, followed by answer items ‘Other good or service’ and 
‘Did not have any problem’ 

S2B - Markets in 
which problems 
experienced* 
(If ‘Yes’ in S1) 

Question: Please look through the list below and indicate all goods or services you 
have experienced a problem with in the last 12 months, either with the goods or 
services or the seller/provider, for which you consider you had a legitimate cause 
for complaint. 

Answer items:  
List of markets assessed, followed by  answer items ‘Other good or service’ and 
‘Did not have any problem’ 

Question: With which of the goods or services listed below did you experience the 
most serious problem (i.e. that caused you the most trouble or cost)? 

Answer items:  
List of markets selected in S2A/S2B 

S3 - Market in which 
most serious problem 
experienced 
(If at least one market 
selected in S2A/S2B) 

Source: Civic Consulting. (*) If the respondent selects one (and only one) relevant market in this question, then he/she 
is then taken to the market module questions. 

If  the  assessment  covers  a  small  number  of  markets  of  a  similar  nature  (e.g.  only 
subscription  services),  the  list  of  examples  of  problems  in  S1  could  be  made  more 
relevant  to  those  market(s)  (e.g.  by  excluding  ‘Later  or  no  delivery’,  in  case  only 
subscription services are assessed). Moreover, it is recommended to use a time period 
of  12  months  as  the  most  appropriate  time  period  to  facilitate  respondent  recall. 
However,  in  a  single-market  assessment  focusing  on  one  market  with  a  relatively 
lower penetration rate (e.g. the mortgages market), a longer period can be applied. A 

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benchmark  in  such  cases  is  the  reference  periods  applied  in  the  European 
Commission’s Market Monitoring Survey/Consumer Markets Scoreboard.24 

Finally,  if  the  assessment  covers  a  large  number  of  markets,  the  markets  in  the 
answer  items  in  S2A/S2B  can  also  be  grouped  according  to  the  clusters  in  the 
Consumer Markets Scoreboard (e.g. ‘Telecoms’, ‘Utilities’, ‘Semi-durable goods’). 

2.2. Market module questions  

The market module refers to a set of market-specific questions aimed at exploring the most serious 
problem(s) experienced by the respondent in depth, in particular in terms of the magnitude of 
financial detriment, time loss and psychological detriment relating to the problem.  

The  market  module  questions  are  thus  only  asked  of  the  sub-sample  of  respondents 
who  experienced  problem(s)  in  at  least  one  of  the  assessed  market(s).  It  is 
recommended  to  develop  one  specific  market  module  for  each  market  assessed 
(assuming  the  markets  are  defined  in  the  same  way  as  in  the  Consumer  Markets 
Scoreboard / Recommendation on consumer complaints).  

If a large number of markets are to be covered, the use of market modules with more 
generically phrased questions could be considered in order to be  suitable for several, 
similar markets - such as for durable consumer goods or for subscription services.  

Moreover, in order to enlarge the sample of respondents who reported problems, one 
option  is  to  ask  respondents  to  identify  the  market  in  which  they  experienced  their 
second most serious problem from the markets subject to assessment (if they indeed 
experienced a second problem in these markets), and thus complete a second market 
module. This can be done via a follow-up question M18, as shown in the table below. 

The  table  below  provides  an  overview  of  the  market  module  questions  applied  in  the 
methodology. 

24 For the list of reference periods, see p.13 in European Commission, Monitoring Consumer Markets in the 
European Union 2013 - Part I, 2013. However, please also refer to recommendation in Section 3 in Annex I 
concerning the reference periods for durable goods. 

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Table 4: Overview of market module question topics. 

Q. 

Question topic 

Magnitude 
measurement 

Contextual 
information 

M1 

M2 

M3 

M4 

M5 

M6 

M7 

M8 

M9 

M9B 

M10 

M11 

M12 

Specific product/service 

Age of good/service 

Amount paid or reference amount for 
good/service 

Sales channel 

Location of the trader 

Problem description 

Over-/extra charges or hidden fees 

Usability of the good or service 

Actions taken by the consumer 

Reasons for not taking action 

Time loss 

Psychological detriment 

Money spent trying to sort out the problem 

M13* 

Estimation of ‘fair price’ for good/service 

M14 

M15 

M16 

M17 

M18** 

Actions taken by the trader 

Amount received as reimbursement/ 
compensation 

Status of the problem 

Duration of the problem 
Market in which 2nd most serious problem 
experienced 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

Source: Civic Consulting. Market module questions are only asked of the sub-sample who experienced problem(s) in the 
assessed market(s). (*) The estimation of ‘fair price’ for good/service is not an essential element of the methodology, 
see Section 6.6.2. of the consumer detriment study. (**) Only applies if survey allows for up to two most serious 
problems to be reported. 

2.2.1. Adaptation of the market module questions 

There are two main types of markets that generally require the same type of market-
specific  adaptations:  goods  markets  and  subscription  services  markets  (i.e.  services 
provided  to  the  consumer  on  a  continuous  basis  in  exchange  for  a  regular  payment 
e.g.  mobile  telephone  service,  electricity, internet,  etc.).  For  markets  that  do  not  fall 
within  either  of  these  two  categories,  there  are  no  uniformly  applicable  question  and 
answer items, such that adaptations of the questionnaire would generally need to be 
specifically  tailored  to  the  market  in  question  (as  was  done  for  the  markets  for  train 
services  and  loans,  credit  and  credit  cards  in  the  consumer  detriment  study). 
Accordingly,  the  adaptations  to  be  applied  for  individual  market  modules  outlined 
below are structured according to goods, subscription services and ‘other services’, the 
latter of which draws on the adaptations proposed for goods and subscription services. 
We also provide examples of questions and answer items for train services and loans 
credit and credit cards in the following subsections. 

Furthermore,  two  adaptations  that  could  be  implemented  at  the  beginning  for  all 
questions of each market module concern the appropriate market-specific wordings for 
traders and the products sold in the market in general terms, as follows: 

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•  Wording  for  trader:  In  goods  markets,  generally  ‘seller’  is  the  most 
appropriate,  in  light  of  its  broad  applicability.  For  subscription  services, 
generally ‘provider’ is most appropriate, although more specific wording can 
be  applied  in  some  cases  (e.g.  electricity  supplier).  For  other  services, 
market-specific wording that is sufficiently broadly applicable to the variety 
of traders in that market (e.g. for consumer credit: ‘credit provider’, which 
covers  both  financial  institutions  and  retailers  offering  store  cards)  may 
need to be developed. 

•  Wording for product: In some cases it is sufficient to apply the name of the 
market  in  the  singular  form,  e.g.  ‘this  mobile  telephone  service’,  ‘this 
electricity service’, ‘this train service’. In some cases shorter wording will be 
needed  e.g.  ‘this  appliance’.  Finally,  in  some  cases  concise  wording  that 
accounts  for  the  diversity  of  products  in  the  market  will  need  to  be 
developed  e.g.  ‘this  item’  for  a  product  in  the  clothing,  footwear  and  bags 
market, or ‘this banking service’ for a product in the loans, credit and credit 
cards market. 

In  the  following  we  explore  the  adaptations  needed  for  each  question  of  the  market 
module. For each question or group of questions, we provide a table that outlines the 
specific  adaptations  needed  according  to  the  three  types  of  markets  –  goods, 
subscription services, and other services, with additional comments to indicate where 
other market-specific changes may be necessary, as well as examples.  

In the tables, [seller/provider] and [good/service] refer to the market-specific wording 
for the trader and product in each market. If there are generic question/input wording 
and/or answer items (i.e. that are applicable across market modules), then these are 
indicated in the column ‘Goods’ (which the ‘Subscription services’ and ‘Other services’ 
then refer to). 

2.2.2.  Identify  relevant  products  for  markets  selected  and  adapt  question  on  the 
specific product/service linked to the problem experienced 

From a policy perspective it is important to know which type(s) of product are linked 
to the problem(s) reported by consumers in the markets assessed. Once the markets 
for assessment are defined, a detailed list of products that constitute a specific market 
should  be  developed  as  a  basis  for  the  first  question  of  the  market  module.  To  this 
end, there are several classification systems of markets and the products they include; 
key  relevant  classification  systems  are  the  ones  outlined  in  the  EC  Recommendation 
on  harmonising  complaints  classification  systems, 
the  Consumer  Market 
Scoreboards, or the United Nations Central Product Classification system.25 If data on 
consumer  complaints  is  used  in  order  to  triangulate  the  results  from  the  consumer 
survey (see Step 3.4 below), it is recommended to use the classification system in the 
Recommendation for the consumer survey, to ensure compatibility. 

in 

In the case of some markets, the list of products in the classification system may not 
be sufficiently granular for assessing the types of problems that are of interest. This is 
particularly  relevant  for  subscription  services,  where  the  lists  of  products  are  rather 
concise,  e.g.  for  electricity  services,  problems  with  both  standalone  electricity 
contracts  and  when  bundled  with  gas  may  be  of  interest.  Another  example  is  the 
market for train services, in which problems with the transport of mobility equipment 
for  disabled  passengers  may  also  be  of  interest.  In  such  cases,  products  should  be 
added to the list or further specified as appropriate. 

25 Available at http://unstats.un.org/unsd/cr/registry/cpc-21.asp 

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The final list of products for the market(s) selected should then act as a basis for the 
answer items in question M1 of each of the market modules of the consumer survey. 
The  table  below  outlines  the  adaptations  for  the  related  question  and  answer  items, 
including  examples  of  answer  items  from  the  market  modules  developed  in  the 
consumer detriment study. 

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Table 5: Question on the specific product/service linked to the problem experienced – M1 

Question 

Goods  

Subscription services  

Other services 

M1 - Specific 
product/service  

Question: With which of the following did you 
experience the problem?  

What type of [service] did you have when you 
experienced the problem? 

Either the question wording for goods or 
subscription services would generally apply.  

Answer items: Answer items should be based 
on the market-specific list of products 
developed.  
The following is an example for the market 
for large household appliances: 

(1) Electric cooker, stove, oven or micro-wave 
oven 

Answer items should be based on the market-specific 
list of products developed. 
The following is an example for the market for 
electricity services: 

Answer items should be based on the market-
specific list of products developed, as in the 
example for the market for loans, credit and 
credit cards below: 

(1) Electricity subscription (with regular payments) 

(1) Loan (e.g. personal loan or car loan)  

(2) Refrigerators, freezer or fridge-freezer 

(2) Prepaid electricity (with payment upfront) 

(2) Credit cards  

(3) Washing machine, dryer or ironing and 
pressing machine 

(3) Electricity as part of a bundle with other services, 
e.g. gas, water, insurance etc. (subscription) 

(3) Store card with credit function  

(4) Dishwasher 

(4) Electricity as part of a bundle with other services, 
e.g. gas, water, insurance etc. (prepaid) 

(4) Other consumer credit  

(5) Air conditioner, humidifier or ventilator 

(5) Other 

(6) Water heater or space heater (e.g. 
radiator) 

(7) Vacuum cleaner or steam-cleaning 
machine 

(8) Carpet shampooing machine or machine 
for scrubbing, waxing and polishing floors 

(9) Sewing machine or knitting machine 

(10) Package of multiple large household 
appliances 

(11) Other 

Depending on the market, it may make sense to 
allow multiple items to be selected, as in the 
example for the market for train services below:  
(1) Travelling by train as passenger  

(2) Transporting a bicycle by train 

(3) Transporting another vehicle by train (e.g. a 
car or a scooter) 

(4) Transporting mobility equipment for disabled 
passengers 

(5) Luggage transport by train 

(6) Other 

Source: Civic Consulting. Note: for detailed scripting instructions, please refer to the consumer survey questionnaire of the consumer detriment study, Annex III.

25 

 
 
 
Study on measuring consumer detriment in the European Union 

2.2.3. Identify relevant problem types for markets selected and adapt question on the 
description of the problem experienced 

In  view  of  targeted  policy  measures  to  address  personal  consumer  detriment 
evidenced  by  the  assessment,  it is  also important  to  know  the  type  of  problems  that 
are  the  cause  of  the  detriment  reported.  A  list  of  types  of  problems  encountered  by 
consumers  in  the  selected  market(s)  should  therefore  be  developed,  to  allow  the 
respondent to identify the type of problem he or she experienced. 

For  the  purposes  of  triangulation  of  the  consumer  survey  data  with  complaints  data, 
the problem types should generally be consistent with the chosen categorisation level 
of the European Commission’s harmonised complaints database.26 Therefore, an initial 
list of common problems satisfying these criteria should be established, on the basis of 
market-specific  literature  and  data  sources  as  well  as  previous  market-specific 
surveys,  if  available.  Following  this,  it  is  recommended  to  consult  the  harmonised 
complaints  database  for  the  market(s)  and  country(ies)  selected  and  rank  the 
complaints data in terms of frequency of complaints, from most to least frequent. The 
most  frequent  complaint  categories  will  then  serve  as  an  indication  as  to  the  most 
relevant problem types for inclusion in the list. 

In the  consumer detriment study, markets  of a similar nature tended to have similar 
rankings of complaint categories. For example, complaints concerning incorrect billing 
were among the highest ranked for electricity services and mobile telephones services, 
i.e.  subscription  services  that  are  typically  paid  for  with  monthly  bills.  In  contrast, 
complaints relating to the delivery of the good or service were highest among clothing 
and footwear and large household appliances. For other types of markets, e.g. loans, 
credit  and  credit  cards  or  train  services,  similarities  with  these  different  types  of 
markets were observed, but were however not systematic.27 

In  addition,  it  is  important  to  note  that  there  may  be  types  of  problems  for  which 
consumers  tend  not  to  lodge  formal  complaints,  but  which  could  nonetheless  be  a 
frequent  source  of  personal  consumer  detriment  or  simply  relevant  to  be  explored 
from a policy perspective (e.g. aggressive selling practices, which generally have a low 
rate of complaints relative to other types of problems). Some problem types are also 
particularly  relevant  for  certain  markets  (e.g.  delays  for  train  services  or  problems 
with repayment schedule for loans, credit and credit cards), while other problem types 
may  be  highly  relevant  from  the  perspective  of  almost  all  markets  (e.g.  misleading 
advertising  or  unsatisfactory  customer  service).  In  this  regard,  it  is  recommended  to 
conduct  interviews  with  relevant  stakeholders  (e.g.  consumer/regulatory  authority  or 
consumer association relevant for the market, academic experts, etc.) to validate and 
refine the initial list of problems before carrying out the survey. 

Furthermore,  the  list  should  only  feature  types  of  problems  that  can  reasonably  be 
considered  a  source  of  revealed  personal  consumer  detriment,  as  per  the  definition 
indicated  above.  This  means  checking  that  the  problems  involve  negative  outcomes 
that consumers generally become aware of following the purchase or use of the good 
or service.28 The nature of the problems should also be such that they would generally 

26  In  the  database,  problems  are  categorised  according  to  two  levels:  Each  level  1  category,  such  as  ‘1. 
Quality  of  goods  and  services’  or  ‘2.  Delivery  of  goods/Provision  of  services’  is  subdivided  into  level  2 
classification categories, such as ‘1.1. Defective, caused damage’ and ‘1.2. Not in conformity with order’. 

27  For  more  detailed  results  of  the  cross-market  assessment  undertaken  in  the  study  on  measuring 
consumer detriment in the European Union, please refer to Section 6 of the final report of that study. 

28  This  also  includes  certain  types  of  problems  that  generally  occur  at  the  pre-contractual  stage,  such  as 
misleading  advertising  or  unclear/complex  tariffs,  but  for  which  the  negative  outcomes  are  actually  only 
apparent to consumers post-purchase. 

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Study on measuring consumer detriment in the European Union 

constitute  a  legitimate  cause  for  complaint  (as  the  screener  questions  require  that 
respondents only report a problem for which they consider they had a legitimate cause 
for complaint). 

Finally, the answer items in the questionnaire corresponding to the problem types are 
best  worded  in  a  way  that  is  generally  familiar  to  respondents  and  reflects  their 
consumer experience. For instance, when referring to a consumer’s right of withdrawal 
after  purchasing  a  household  appliance  not  being  honoured  by  the  seller,  the 
corresponding answer item might be ‘Could not return the appliance when I  changed 
my  mind  after  buying’.  Examples  in  parenthesis  also  help  to  make  the  problem  type 
familiar to respondents, e.g. for electricity services: ‘Was charged for services I didn't 
purchase (e.g. extra options or bundled services)’ or for loans, credit and credit cards: 
‘Unclear or complex pricing (e.g. different types of interest rate)’. 

The final list for the market(s) should include as few distinct problem types as possible 
(to  avoid  overly  complex  questionnaires),  which  will  then  act  as  a  basis  for  question 
M6  in  the  corresponding  market  module.29  Furthermore,  it  is  recommended  to  group 
the problem types under broader categories that are as consistent as possible with the 
level 1 problem categories of the complaints database. 30 This allows the respondent to 
more  readily  identify  his/her  problem  in  the  list  and,  if  using  complaints  data  as  a 
triangulation  tool,  facilitates  the  comparison  of  frequency  of  complaints  with  the 
frequency  of  the  corresponding  problem  type  in  the  consumer  survey  (see  Step  3.4 
below on the approach to triangulation for more details).  

The table below outlines the related question and answer items depending on the type 
of market, including examples of answer items. 

29 It is not necessary for the problem types to be mutually exclusive. Indeed, what survey respondents may 
consider to constitute a single problem they experienced may in fact relate to multiple problem types, e.g. 
late delivery combined with poor customer service. 

30 In the study, while the level 1 complaint categories of the harmonised database were used as a basis for 
the  labelling  of  the  groupings  of  problem  types,  the  labels  are  not  identical  to  the  level  1  complaints 
categories. 

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Study on measuring consumer detriment in the European Union 

Table 6: Question on the description of the problem experienced – M6 31 

Question  Goods  

M6 - 
Problem 
description  

Question: Which of the items below describe the 
problem with the [good/service] or with the 
[seller/provider] you obtained it from? Mark all that 
apply. 

Answer items: Answer items should be based on the 
market-specific list of problem types developed, 
grouped under broader categories e.g. ‘Quality’, 
‘Delivery’, etc. The following is an example for the 
market for large household appliances: 

Subscription services  

See column 'Goods' 

Other services  

See column 'Goods' 

The following is an example for the market for mobile 
telephone services: 

The following is an example for the market for 
loans, credit and credit cards: 

Quality 

Quality and provision of service  

Provision of loan/credit card 

(1) Appliance faulty or broke down (without me 
causing the damage) 
(2) Appliance or instructions of unsatisfactory quality 
or appliance not as described 

(1) Mobile telephone connection of unsatisfactory 
quality (e.g. signal, coverage, etc.) 
(2) Phone provided with contract faulty or not as 
described 

Guarantee/warranty  
(3) Guarantee/warranty not honoured by seller  

(3) Mobile telephone service provided late  

(1) Loan or credit card not at all provided or only 
partially provided (e.g. impossible to use credit 
card) 

Customer service 

Customer service 

Customer service 

(4) Poor customer or after-sales service 

(4) Poor customer or after-sales service 

(2) Poor customer service (e.g. unsatisfactory 
assistance) 

Pricing 

Tariffs 

Pricing 

(5) Unclear or complex pricing 

(5) Unclear or complex tariffs 

(3) Unclear or complex pricing (e.g. different types 
of interest rate) 

Billing and payments 

Billing and payments 

Payments 

(6) Bill incorrect (e.g. I was overcharged) 

(6) Bill incorrect (e.g. I was overcharged, wrong tariff 

(4) Payments charged incorrect (e.g. charges not 

31 Please note that questions M2 to M5 are presented in Table 92 below. 

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Study on measuring consumer detriment in the European Union 

applied or credit not reimbursed) 

(7) Bill not received/not accessible 

applied correctly, or I was overcharged) 

(5) Problems with loan/credit repayment schedule  

(7) Disproportionate fees applied for late payment 

(8) Disproportionate fees (e.g. for late payment) 

(6) Disproportionate fees applied for late payment  

Misleading or aggressive commercial practices 

Misleading or aggressive commercial practices 

Misleading or aggressive commercial practices 

(8) Misleading or incorrect indication of price (e.g. 
hidden charges) 

(9) Misleading or incorrect indication of price (e.g. 
hidden charges) 

(7) Misleading or incorrect indication of the costs 
of credit (e.g. hidden charges) 

(9) Advertising was misleading 

(10) Advertising was misleading 

(10) Received false advice when buying appliance 

(11) Received false advice when signing the contract 

(11) Was put under pressure when buying the 
appliance 

(12) Was put under pressure when signing up to the 
mobile telephone service or in case of late payment 

(8) Advertising was misleading (e.g. failure to 
provide the advertised benefits) 

(9) Received false advice when signing the 
contract/applying for the loan 

(10) Was put under pressure when signing the 
contract, applying for or extending the loan (e.g. 
harassment or excessive advertising)  

(13) Was provided (other) services I didn’t request 

(11) Was provided other services I didn't request 

Contractual issues 

Contractual issues  

Contractual issues  

(12) Missing or incomplete information in the contract 
(e.g. concerning right of withdrawal or identity of 
seller) 

(14) Missing or incomplete information in the contract 
(e.g. duration, conditions for termination, identity of 
the provider, etc.) 

(12) Missing or incomplete information in the 
contract (e.g. duration, conditions for termination, 
identity of the credit provider, etc.) 

(13) Could not return the appliance when I changed 
my mind after buying 

(15) Could not cancel the contract within the cooling-
off period  

(13) Could not withdraw within the  cooling-off 
period after signing the contract  

(14) Other problem 

(16) Problems terminating my contract or switching 
tariff  

(14) Problems with termination of my contract or 
early repayment  

Damage or injury 
(15) Appliance caused damage to other possessions 
(16) Appliance caused injury 

(17) Contractual terms unfair or changed by service 
provider without my consent (e.g. increase in price) 
(18) Contract was renewed without prior notice 

(15) Contractual terms not provided, unfair or 
changed by credit provider without my consent 
(e.g. unexplained refusal to continue credit 
provision) 

Delivery 

Switching provider  

Fraud 

(17) Appliance not delivered 

(19) Problems switching to another provider  

(16) Fraudulent use of credit card 

(18) Appliance delivered late or only partially 
delivered 

(20) Other problem 

(17) Other problem 

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Study on measuring consumer detriment in the European Union 

2.2.4.  Establish  dimensions  of  personal  consumer  detriment  to  measure  and  adapt 
relevant questions 

While time loss and psychological detriment each depend on one question in the questionnaire (M10 
and M11 respectively), financial detriment on the other hand requires multiple questions to be 
measured (M3, M7, M8, M9, M12 and M17).  

Furthermore, to estimate post-redress financial detriment (i.e. financial detriment net 
of  any  redress  that  was  received)  two  more  questions  are  needed  (M14  and  M15). 
Each of these questions is essential for an estimation of financial detriment, while M9 
and M14 also provide additional information on the context. 32 In total, the assessment 
of detriment therefore requires a minimum of ten survey questions (not including the 
screener  with  three  questions).  In  the  following  we  further  describe  each  of  the 
dimensions of detriment and the related adaptations for the questionnaire. 

Pre-redress financial detriment 

The methodology of the consumer detriment study was developed to collect data that 
allows both pre- and post-redress financial detriment to be calculated. While previous 
assessments  of  detriment  focused  on  the  measurement  of  financial  detriment  net  of 
any redress that was received, the distinction between pre- and post-redress financial 
detriment  allows  for  a  better  assessment  of  the  level  of  redress  obtained  by 
consumers as well as the costs associated with seeking redress.  

The pre-redress stage is considered to cover all financial losses resulting directly from the problem as 
well as the actions taken by the consumer to sort out the problem and their related costs, but 
excludes any actions taken by the trader to sort out the problem. 

At  the  pre-redress  stage,  financial  losses  resulting  directly  from  the  problem  might 
include: 

•  Over-/extra charges or hidden fees (e.g. because of an incorrect bill); 

•  Potential reduction in value of the good or service because it cannot be 

used as intended (e.g. because it is faulty). 33  

Moreover, costs of sorting out the problem might include:  

•  Costs of repairing/replacing a good or buying an alternative service at the 

consumer’s own expense; 

•  Costs related to court proceedings;  

•  Other costs such as costs of telephone, postage, or travel to sort out the 

problem. 

32  For  details  on  the  rationale  for  the  questions  involved  in  the  measurement  of  financial  detriment,  see 
Section 4.9.4. of the final report of the study. 

33 For markets other than goods and subscription services markets, such as the market for loans, credit and 
credit  cards,  reduction  in  value  or  loss  of  service  is  not  relevant.  However  this  does  not  limit  the 
comparability of results  across  markets,  as  the  methodology developed  covers  all  the main  ways  in which 
financial detriment occurs, regardless of the market. 

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The  questions  in  the  table  below  have  been  designed  to  gather  information  on  these 
key types of costs and losses relating to pre-redress financial detriment (the approach 
to assessment based on the data collected in these questions is outlined in Step 3.2). 
The table also outlines examples of answer items (for questions M3, M7, M8, M9, M12 
and M17).  

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Table 7: Questions related to the assessment of pre-redress financial detriment - M3, M7, M8, M9, M12 and M17 

Question  

Goods  

Subscription services  

Other services  

M3 - Amount 
paid or 
reference 
amount for 
good or 
service 

Question: How much did you pay for this [good] 
(NOT including any over-/extra charges, if 
applicable)? If you are not sure, please give an 
estimate. 

Input field: Please indicate the amount paid: … 

How much did/do you pay for this [service] (NOT 
including any over-/extra charges if applicable)? If you 
are not sure, please give an estimate. 

Please indicate the amount paid on average per 
month:  
For some subscription services, such as electricity 
services, other periods of reference could be offered 
to account for the full range of possibilities in the 
countries assessed (e.g. quarterly or yearly payments). 

For services involving a one-time purchase (e.g. a 
train ticket), the same adaptation as for goods 
would apply. For specific services a reference type 
of amount may need to be specified (e.g. for 
credit cards: ‘What is the spending limit on this 
credit card or store card?’).  

Tick box: I didn’t pay for this [good] 

I didn’t/don’t pay for this [service] 

M7 - Over-
/extra 
charges or 
hidden fees* 

Question: How much did you pay in total in over-
/extra charges or hidden fees (do not consider any 
reimbursement you may have received from the 
[seller/provider]) as a result of the problem? Mark 
0 if you did not pay any over-/extra charges or 
hidden fees.**  

See column 'Goods' 

See column 'Goods' 

Input field: Please indicate the amount paid: … 

See column 'Goods' 

See column 'Goods' 

M8 - Usability 
of the good 
or service* 

Question: To what extent could you use the [good] 
as intended after the problem occurred? 

During the period the problem lasted, to what extent 
could you use the [service] as intended? 

Answer items:  

(1) Not at all 

(2) Partly, with major difficulty 

(3) Partly, with minor difficulty 

(4) Fully 

See column 'Goods' 

For services involving a one-time purchase (e.g. a 
train ticket), the same adaptation as for goods 
would apply, potentially excluding the words 
‘after the problem occurred’. For services for 
which usability is not a relevant characteristic (e.g. 
loans, credit cards), exclude this question. 

M9 - Actions 
taken by the 
consumer 

Question: Which of these, if any, have you done to 
sort out the problem? Mark all that apply 
Answer items: 

See column 'Goods' 

See column 'Goods' 

Generally, either the answer items for goods or 

32 

 
 
 
 
Study on measuring consumer detriment in the European Union 

Question  

Goods  

Subscription services  

Other services  

subscription services would generally apply. In 
specific cases, you may need to further adapt or 
add answer items relevant to the nature of the 
market and the policy/legal framework, e.g. for 
train service ‘Paid for alternative transport (e.g. 
bus, taxi, plane, boat)’; ‘Asked the seller/provider 
to provide transport continuation or re-rerouting’ 
or for loans, credit and credit cards ‘Cancelled the 
contract within the cooling-off period (14 days 
from when I signed up)’ (regardless of whether 
the respondent signed up online or otherwise). 

(1) Cancelled the purchase of the [good] within the 
cooling-off period (14 days from when I signed up 
online)  

(1) Cancelled the [service] within the cooling-off period 
(14 days from when I signed up online) 

(2) Returned the [good] 

(2) Terminated the [service] contract 

(3) Repaired the [good] at my own expense. For 
goods for which repairs or returns are not relevant 
(e.g. fast moving consumers goods such as fruit 
and vegetables), the related answer items should 
be excluded 

(4) Bought a replacement [good] 

(3) Signed up to an alternative [seller/provider] 

(4) Generally not relevant for this type of market, 
however if the nature of the service is such that the 
consumer could potentially get it repaired at his/her 
own expense (e.g. electricity service), then include: 
‘Got the [service] repaired at my own expense’ 

(5) Withheld payment for the [good/service] 

See column 'Goods' 

(6) Made a complaint to the [seller/provider] 

See column 'Goods' 

(7) Asked the [seller/provider] for repair, 
replacement or refund of the money I paid 

(7) Asked the [seller/provider] for replacement or 
refund of the money I paid 

(8) Asked the [seller/provider] for compensation for 
damages or losses 

See column 'Goods' 

(9) Made a complaint to a government body or 
consumer organisation 

(10)Took the [seller/provider] to an out-of-court 
dispute settlement /alternative dispute resolution 
body (ADR) 

(11) Took the [seller/provider] to court 

(12) Other action 

(13) Have not taken any action 

See column 'Goods' 

See column 'Goods' 

See column 'Goods' 

See column 'Goods' 

See column 'Goods' 

33 

 
 
 
 
Study on measuring consumer detriment in the European Union 

Question  

Goods  

M12 - Money 
spent trying 
to sort out 
the problem 

Question: How much money have you spent trying 
to sort out the problem, without considering any 
reimbursement or compensation you may have 
received from the [seller/provider]? Please provide 
an estimate for the following possible cost items. 

Subscription services  

See column 'Goods' 

Other services  

See column 'Goods' 

(1) Costs of repairs or replacement at your own 
expense. For goods for which repairs are not 
relevant (e.g. fast moving consumer goods such as 
food), this should be shortened to ‘Costs of 
replacement at your own expense’. [Input field] 

(1) Costs of replacement [service]. If the nature of the 
service is such that the consumer could potentially get 
it repaired (e.g. electricity service), then apply the 
same adaptation as for goods. 

(1) Depending on the market, either ‘Costs of a 
replacement [service]’, ‘Costs of an alternative 
[service]’ or a mix of both would apply (e.g. for 
loans, credit cards ‘Extra costs for an alternative 
banking service’ or for train services ‘Costs of 
replacement ticket/alternative transport’) 

(2) Costs of court proceedings. [Input field]*** 

(2) See column 'Goods' 

(2) See column 'Goods' 

M17 – 
Duration of 
the problem 

(3) Other extra costs relating to e.g. telephone, 
postage, travel costs to sort out the problem, 
expert advice, etc. [Input field] 

(3) See column 'Goods' 

Question: How long did the problem last? 

See column 'Goods' 

See column 'Goods' 

Answer items: 

(1) Less than one day 

(2) One day to less than a week 

(3) One week to less than one month 

(4) One month to less than three months 

(5) Three months to less than six months 

(6) Six months to less than a year 

(7) A year or more 

(3) See column 'Goods'. In specific cases, 
additional market-specific cost item examples can 
be added (e.g. for train services, ‘accommodation 
and meals’). 

See column 'Goods' 

See column 'Goods' 

Source: Civic Consulting. Notes: for detailed scripting instructions, please refer the consumer survey questionnaire of the consumer detriment study in Annex III. (*) While this question was only asked 
to respondents who selected relevant problem types in M6, it is recommended to pose this question to all respondents, as removing very specific filters makes the implementation of the survey and 
the analysis of results simpler, however making the questionnaire on average longer for respondents. (**) The wording here is a slight modification from the wording of the consumer survey 
questionnaire used in the consumer detriment study. (***) As only a small number of respondents reported ‘Costs of court proceedings’ in the consumer detriment study, it is recommended to 
subsume this item under ‘Other extra costs e.g. telephone, postage, legal costs, …’, if such costs are not specifically relevant to the market or study in question. 

34 

 
 
 
Study on measuring consumer detriment in the European Union 

Redress and post-redress financial detriment 

The post-redress stage considers all actions taken by the trader to solve the problem (i.e. any 
substantial redress provided by the trader to the consumer).  

The substantial redress may partly or wholly offset the financial detriment suffered by 
the consumer at the pre-redress stage. It may consist of:  

•  Repairs, replacement goods or alternative services provided by the trader 

to the consumer; and/or  

•  Monetary redress, i.e. partial or full refund, credit note, voucher, or 

compensation provided by the trader to the consumer.  

The table below outlines the adaptations required for the questions and answer items 
collecting data on redress (M14 and M15) for the purposes of calculating post-redress 
financial  detriment  (i.e.  financial  detriment  net  of  any  redress  received),  including 
examples  of  answer  items  from  the  market  modules  developed  in  the  consumer 
detriment study. 

35 

 
 
 
 
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Table 8: Questions relating to redress/post-redress financial detriment – M14 and M15 

Question  

Goods  

M14 – Actions 
taken by the 
trader 

Question: Which of these, if any, has the [seller/provider] done so far 
in response to the problem? 

Answer items: 

(1) Acknowledged problem 

(2) Investigating problem 

(3) Gave a satisfactory explanation 

(4) Gave an unsatisfactory explanation 

(5) Repaired or replaced [good] 

Subscription services  

Other services  

See column 'Goods' 

See column 'Goods' 

(1) See column 'Goods' 

(1) See column 'Goods' 

(2) See column 'Goods' 

(2) See column 'Goods' 

(3) See column 'Goods' 

(3) See column 'Goods' 

(4) See column 'Goods' 

(4) See column 'Goods' 

(5) Fixed/repaired [service] 

(5) Provided alternative [service] 

(6) Item not relevant for this type of market; see other columns 

(6) Provided a new tariff/contract 

(6) Gave replacement [service] 

(7) Gave a partial or full refund of the money I paid 

(7) See column 'Goods' 

(7) See column 'Goods'. Items relating to 
reimb./comp. may need to be more specific. 

(8) Gave credit note or voucher 

(8) See column 'Goods' 

(8) See column 'Goods' 

(9) Gave compensation for damages or losses 

(9) See column 'Goods' 

(9) See column 'Goods' 

(10) Told me that my legal guarantee was no longer valid. (If a legal 
guarantee applies to the good) 

(10) Item not relevant for this 
type of market 

(10) Item not relevant for this type of market 

(11) Other 

(11) See column 'Goods' 

(11) See column 'Goods'.  If relevant, market-
specific additional answer items can be included 

(12) Has done nothing 

(12) See column 'Goods' 

(12) See column 'Goods' 

Question: How much have you received as reimbursement (e.g. 
refund, credit note or voucher) or compensation for the problem from 
the [seller/provider]? If you are not sure, please give an estimate. 

See column 'Goods' 

For services in which credit notes or vouchers are 
generally not relevant (e.g. loans, credit cards), a 
reference to these should be excluded. 

Input field: Please indicate the amount 

See column 'Goods' 

See column 'Goods' 

M15 – Amount 
received as 
reimbursement 
or 
compensation* 

Source: Civic Consulting. Notes: for detailed scripting instructions, please refer the consumer survey questionnaire of the consumer detriment study in Annex III. (*) While in the consumer detriment 
study this question was only asked to respondents who indicated they received reimbursement or compensation in M14, for future assessments our recommendation is to pose this question to all 
respondents, regardless of their responses to M14. 

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Time loss, psychological detriment  

The  following  table  outlines  the  adaptations  required  for  the  questions  and  answer 
items  relating  to  the  other  dimensions  of  personal  consumer  detriment  (M10,  M11) 
including examples of answer items. 

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Table 9: Questions relating to time loss and psychological detriment – M10, M11 

Question  

Goods  

Subscription services  

Other services  

M10 – Time loss 

Question: What is the total amount of time you 
have personally lost as a result of the problem, 
e.g. by being delayed, discussing the problem, 
contacting the [seller/provider], going to an 
alternative dispute resolution body or to court, 
repairing or replacing the [good] etc.? 

What is the total amount of time you have 
personally lost as a result of the problem, e.g. by 
being delayed, discussing the problem, contacting 
the [seller/provider], going to an alternative 
dispute resolution body or to court, replacing the 
[service]/looking for an alternative etc.? 

Generally the same adaptation as for 
subscription services would apply. In specific 
cases, an additional market-specific example 
of time loss can be included, e.g. for train 
services ‘complaining to the national authority 
in charge of enforcing passenger rights’. 

See column 'Goods' 

See column 'Goods' 

Answer items: 

(1) Less than 1 hour 

(2) 1 to 2 hours 

(3) 3 to 4 hours 

(4) 5 to 10 hours 

(5) 11 to 20 hours 

(6) More than 20 hours 

(7) No time lost 

M11 – Psychological 
detriment 

Question: To what extent have you felt 
emotionally stressed e.g. angered, frustrated or 
worried as a result of the problem? 

See column 'Goods' 

See column 'Goods' 

Answer items:  

(1) Not at all or only a little 

(2) Moderately 

(3) Quite a lot 

(4) Extremely 

See column 'Goods' 

See column 'Goods' 

Source: Civic Consulting. Notes: for detailed scripting instructions, please refer the consumer survey questionnaire of the consumer detriment study in Annex III. 

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2.2.5.  Establish  additional  contextual  information  to  assess  and  adapt  relevant 
questions 

Beyond  the  assessment  of  magnitude  of  personal  consumer  detriment,  additional 
questions  are  included  in  the  methodology  to  provide  further  information  on  the 
context  in  which  the  detriment  was  experienced.  This  relates  to  both  information 
about the purchase, such as how long ago the good/service was purchased (M2), the 
sales channel used  for  the purchase (M4), the location of the trader (M5), as  well as 
additional information about the problem and how the respondent dealt with it – such 
as reasons for not taking action (M9B, applicable for respondents who selected ‘Have 
not taken action’ in M9 – Actions taken by the consumer), or the status of the problem 
(M16). As these questions are not essential for the calculation of consumer detriment, 
they are optional and their inclusion in a survey is likely to depend on policy priorities 
and feasibility. 

Contextual information relating to the purchase of the good or service 

The  table  below  outlines  the  adaptations  required  for  question  and  answer  items  on 
contextual information relating to the purchase of the good or service: how long ago it 
was purchased (M2), the sales channel used for the purchase (M4), and the location of 
the  trader  (M5).  It  includes  examples  of  answer  items  from  the  market  modules 
developed in the consumer detriment study.  

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Table 10: Questions on contextual information on the purchase of the good or service– M2, M4, and M5 

Question topic  Goods 

Subscription services 

Other services 

M2 - Age of 
good/service 

Question: When did you buy this [good]? 
If second-hand purchases are relevant for the market, 
add ‘If you purchased the [good] second-hand, please 
indicate when it was first sold.’  

When did you sign up to this [service]? 

Generally, either the question wording for goods or 
subscription services would apply.  

Answer items: 

See column 'Goods' 

(1) Less than 6 months ago 

(2) 6 months to less than 12 months ago 

(3) 12 months to less than 24 months ago 

(4) 2 years to less than 5 years ago 

(5) 5 years ago or more 

M4 - Sales 
channel 

Question: How did you purchase this [good]? 

How did you sign up to this [service]? 

Answer items: 

See column 'Goods' 

(1) In person, at a shop or other sales point 

(2) Over the Internet, directly from the [seller/provider] 

(3) Over the Internet, through an intermediary (e.g. 
comparison website) 

(4) By mail order, delivery or postal services 

(5) By telephone 

(6) From a salesperson visiting the home 

(7) At a market or auction 

(8) TV shopping channel 

(9) Other 

(7) Item not relevant  

(8) Item not relevant  

For services of one-time use that are generally used 
shortly after purchase (e.g. train services), the following 
answer items can be considered instead: 

(1) Less than 1 month ago 

(2) 1 month to less than 3 months ago 

(3) 3 months to less than 6 months ago 

(4) 6 months to less than 12 months ago 

(5) 12 months to less than 24 months ago 

(6) 2 years ago or more 

Generally, either the question wording for goods or 
subscription services would apply. 

The generic answer items would apply, if relevant with 
specific wording, e.g. for train services ‘(1) In person, at 
a railway station, travel agency or other sales point’. If 
greater precision is needed for offline sales channels, 
two answer items could be applied e.g. for loans, credit 
and credit cards: ‘(1) In person, at a bank or other 
financial institution’ and ‘In person, at a retailer’. For 
insurance services for instance, one might distinguish 
between brokers and insurance agents. 

40 

 
 
 
 
 
 
Study on measuring consumer detriment in the European Union 

Question topic  Goods 

Subscription services 

Other services 

M5 - Location of 
the trader 

Question: Did you obtain this [good] from a 
[seller/provider] based in your country of residence, in 
another EU country, or outside the EU? 

Did you sign up to this [service] from a 
[seller/provider] based in your country of 
residence, in another EU country, or 
outside the EU? 
If cross-border purchases of the 
subscription service remain relatively 
rare (e.g. electricity services), consider 
excluding this question. 

Generally, either the question wording for goods or 
subscription services would apply. In the specific case 
of transport services, different question wording may 
make more sense, e.g. for train services ‘What type of 
train service did you have?’ 

Answer items:  

See column 'Goods' 

(1) [Seller/provider] based in my country of residence 

(2) [Seller/provider] based in another EU country 

(3) [Seller/provider] based outside the EU 

If the question wording is adapted as above, apply 
corresponding answer items instead. E.g. for the 
market for train services: 

1) International 

(2) National 

(3) Regional 

(4) Urban or suburban 

Source: Civic Consulting. Note: for detailed scripting instructions, please refer to the consumer survey questionnaire of the consumer detriment study, Annex III.

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Study on measuring consumer detriment in the European Union 

Other contextual information relating to the problem 

The  table  below  outlines  the  adaptations  required  for  question  and  answer  items  on 
other contextual information relating to the problem – such as reasons for not taking 
action (M9B, applicable for respondents who selected ‘Have not taken action’ in M9 – 
Actions taken by the consumer) or the status of the problem (M16).  

As  these  questions  are  not  essential  for  the  calculation  of  consumer  detriment,  they 
are optional and their inclusion in a survey is likely to depend on policy priorities and 
feasibility.

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Study on measuring consumer detriment in the European Union 

Table 11: Questions on other contextual information relating to the problem –M9B and M16 

Question topic  Goods  

M9B - Reasons for 
not taking action* 

Question: For which of the reasons below have you not taken action? Mark all 
that apply. 

Subscription services  

Other services 

See column 'Goods' 

See column 'Goods' 

Answer items: 

See column 'Goods' 

See column 'Goods' 

(1) I was unlikely to get a satisfactory solution to the problem encountered 

(2) The sums involved were too small 

(3) I did not know how or where to complain 

(4) I was not sure of my rights as a passenger 

(5) I thought it would take too long 

(6) I tried to complain about other problems in the past but was not successful 

(7) I thought complaining would have led to a confrontation, and I do not feel at 
ease in such situations 

(8) The complaints procedure was too complicated 

(9) [Seller/provider] fixed the problem on its own initiative 

(10) I have not had the time yet 

(11) Other 

Question: To what extent has the problem been resolved? 

Answer items: 

(1) Fully resolved 

(2) Partly resolved 

M16 – Status of 
the problem 

(3) Not yet resolved but I was informed that the investigation was ongoing 

(4) Not yet resolved and I have not received any reply 

(5) Not resolved and I decided not to do anything about it  

See column 'Goods' 

See column 'Goods' 

See column 'Goods' 

See column 'Goods' 

Source: Civic Consulting. (*) This question is only asked of respondents who select ‘Have not taken any action’ in M9.Note: for detailed scripting instructions, please refer the consumer survey 
questionnaire of the consumer detriment study in Annex III.

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2.3. Questions on socio-demographics and consumer expectations 

Finally, the socio-demographic questions provide further details on the characteristics 
of  the  respondent,  and  can  be  complemented  by  a  control  question  on  consumer 
expectations. 

The  table  below  provides  an  overview  of  the  questions  applied  in  the  consumer 
detriment study. 

Table 12: Socio-demographic questions, including question on expectations 

Q. 

Question topic 

Contextual information 

D1 

D2 

D3 

D4 

D5 

D6 

D7 

D8 

D9 

Gender 

Age 

Region 

Consumer expectations 

Locality 

Education level 

Occupation 

Financial situation 

Frequency of internet use 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

Source: Civic Consulting. Depending on the requirements of the study, questions can either be asked to the entire 
sample or to the sub-sample who experienced problem(s) in the assessed market(s). 

Socio-demographic  questions  are  used  for  setting  quotas  and  describing  the 
composition  of  the  sample.  These  questions  also  provide  additional  context  to  the 
personal  consumer  detriment  reported,  for  use  in  the  analysis  of  the  results,  e.g. 
through  cross-tabulations  or  advanced  statistical  analysis.34  They  could  include 
questions  on  the  gender  (D1),  age  (D2),  region  (D3),  locality  (D5),  education  level 
(D6), occupation (D7) and financial situation (D8) of the consumer as well as a control 
question on consumer expectations (D4). This information is essential for determining 
which types of  consumers suffer  from detriment most, particularly as these variables 
cover  several  key  drivers  of  consumer  vulnerability  (e.g.  old  age,  low  educational 
attainment,  difficult  financial  situation).  If  conducting  a  face-to-face  survey,  an 
additional  question  on  internet  use  (D9)  could  be  considered.  Socio-demographic 
questions are identical across markets. 

34 For an example, please refer to the results presented in Section 6 of the report of the study on measuring 
consumer detriment in the European Union. 

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Study on measuring consumer detriment in the European Union 

Table 13: Socio-demographic and control questions – D1, D2, D3, D4, D5, D6, D7, D8, D9 

Question 
topic 

D1 - Gender 

Question  

Answer items 

No additional text required. 

(1) Male 
(2) Female 

D2 - Age 

How old are you? 

Input field: No additional text required. 

D3 - Region 

In which region do you live? 

Answer items should be based on a country-specific list of regions. As a basis for the list of regions, it is 
recommended to use the country regions defined as per the NUTS (Nomenclature of Territorial Units for 
Statistics) at level 2 (i.e. NUTS 2) as a basis. 

D4 – Consumer 
expectations * 

Please indicate to what extent you agree or 
disagree with each of the following 
statements. 

Respondents select either ‘Totally agree’, ‘Tend to agree’, ‘Tend to disagree’ or ‘Totally disagree’ for each item: 
(1) Consumers should NOT always expect a high level of good or service quality, even if they pay a premium price 
(2) Consumers should NOT expect to be compensated if something goes wrong with a good or a service 
(3) Consumers should NOT expect to have access to customer service whenever they need it 

D5 - Locality 

Would you say you live in a rural area or 
village, small or middle sized town, or large 
town or city? 

(1) Rural area or village 
(2) Small or middle-sized town 
(3) Large town or city 

D6 – Education 
level 

What is the highest level of education you 
have achieved? 

Answer items should be based on a country-specific list of education levels. As a basis for the list of education 
levels, it is recommended to use the country-specific national ISCED (International Standard Classification of 
Education) levels. 

D7- Occupation  What is your current occupation?  

(1) Self-employed 
(2) Manager 
(3) Other white collar 
(4) Blue collar 
(5) Student 
(6) House-person and other not in employment 
(7) Seeking a job 
(8) Retired 

D8 – Financial 
situation 

Thinking about your household’s financial 
situation would you say that making ends 
meet every month is…? 

(1) Very difficult 
(2) Fairly difficult 
(3) Fairly easy 
(4) Very easy 

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D9 – Frequency 
of internet use 

Question: How frequently do you use the 
internet? 

(1) Every day or almost every day 
(2) Once a week 
(3) 2 or 3 times a month 
(4) Once a month 
(5) A couple of times a year or less often 
(6) Never 

Source: Civic Consulting. Note: for detailed scripting instructions, please refer to the consumer survey questionnaire of the consumer detriment study, Annex III. (*) Based on the results of D4, 
groupings that correspond to different levels of expectations can be created. Because these statements are worded in a negative form, respondents with average or high expectations regarding the 
items are expected to disagree with the statements, i.e. select either ‘tend to disagree’ or ‘totally disagree’. On the contrary, agreement with the statements, i.e. selecting either ‘tend to agree’ or 
‘totally agree’, indicates lower expectation regarding these aspects. Please refer to the results in section 6.8.10. of the consumer detriment study for an example.

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The  table  below  provides  an  overview  of  the  questions  and  relevant  answer  items  in 
the questionnaire used in the consumer detriment study that relate to specific factors 
associated  with  drivers  of  vulnerability.  As  indicated,  these  are  a  mix  of  socio-
demographic  questions  and  market  module  questions  on  contextual  information 
relating to the problem. 

Table 14: Factors/drivers of consumer vulnerability and related questions 

Factor/driver of 
vulnerability 

Survey question 

Answer item that could indicate 
consumer vulnerability 

Age 

Education 

D2- How old are you? 

Highest age category 

D5 - What is the highest level of 
education you have achieved? 

Primary education 
Lower secondary education 
Upper secondary education 

Occupational status 

D6 - What is your current 
occupation? 

Financial situation of 
the household 

Willingness to take 
risks 

D8 - Thinking about your 
household’s financial situation 
would you say that making ends 
meet every month is…? 

M9 - Which of these, if any, have 
you done to sort out the problem? 
Mark all that apply. 

M9bis - For which of the reasons 
below have you not taken action? 
Mark all that apply. 

Frequency of 
internet use 

D9 – How frequently do you use the 
internet? 

Source: Civic Consulting. 

Seeking a job 
Retired 

Very difficult 
Fairly difficult 

Have not taken any action 

I did not know how or where to complain 
I was not sure of my rights as a consumer 
I tried to complain about other problems in 
the past but was not successful 
I thought complaining would have led to a 
confrontation, and I do not feel at ease in 
such situations 

Once a month 
A couple of times a year or less often 
Never 

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Step 3 - Assessment of detriment, triangulation and extrapolation 

After the implementation of the consumer survey and the collection of complementary 
data  (e.g.  regarding  consumer  complaints),  the  subsequent  steps  for  measuring 
personal consumer detriment are as follows: 

•  Assessment of incidence and magnitude of personal consumer detriment in 
the market(s) and country(ies) subject to analysis, based on the results of 
the consumer survey conducted in these country(ies); 

•  Triangulation  of  results  in  these  market(s)  and  country(ies),  for  example 

based on complaints data; and 

•  Extrapolation  of  the  results  to  EU  level  (and  Norway  and  Iceland,  where 

applicable), based on relevant Eurostat data and data from the MMS.  

The  following  diagram  provides  an  overview  of  this  process  as  well  as  the  data 
collection tools/data sources involved in each step. 

Figure  3:  Approach  for  assessment,  triangulation  and  extrapolation  of 
personal consumer detriment 

Assessment 
•Consumer survey 

Triangulation 
•Complaints data 
•Review of literature and 

previous surveys and reports 

•Interviews 
•Mystery shopping exercises 
•Court awards 

Extrapolation 
•Country level data 
•EU wide data 
•Eurostat data (population 

size, price index) and 
Consumer Markets 
Scoreboard data 

Source: Civic Consulting. Triangulation and extrapolation steps are optional and depend on scope and objectives of the 
assessment. 

The implementation of each of these steps is described based on the approach used in 
the consumer detriment study; further details are provided in Sections 4 and 5 of the 
main report of the consumer detriment study. 

3.1. Measure the incidence of detriment 

As  indicated  before,  the  incidence  of  personal  consumer  detriment  refers  to  the 
number  of  respondents  to  the  consumer  survey  who  report  having  experienced  a 
problem for which they had a legitimate cause for complaint in a given time period, as 
a percentage of the total sample surveyed. Incidence of personal consumer detriment 

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Study on measuring consumer detriment in the European Union 

in  the  markets  subject  to  assessment  is  calculated  on  the  basis  of  the  screener 
questions.35  

The incidence of problems experienced by consumers in a given market is calculated as the combined 
total of the number of respondents who ‘ticked’ that market in questions S2A or in S2B, as a 
percentage of the total survey sample. 

3.2. Measure the magnitude of detriment 

3.2.1. Financial detriment calculation 

The  different  elements  of  consumer  detriment  necessary  for  the  calculation  of  pre-
redress  financial  detriment,  substantial  redress  and  post-redress  financial  detriment 
are  either  based  on  monetary  data  directly  reported  by  respondents  or  calculated 
based  on  answers  provided  by  respondents  across  multiple  questions.  The  following 
provides an overview of the approach. 36 

The calculation of pre-redress financial detriment involves the following elements, 
which are calculated separately for each respondent: 

1)  Reduction  in  value  or  loss  of  service  relating  to  loss  in  usability  of  a  good  or 
service, as a result of the problem. This can be calculated by using the answers 
to M8 to first assign an index value between 0 and 1 to usability of the good or 
service. The reduction in value relating to the loss in usability is then equal to 
the price reported in M3 multiplied by the index value for the loss in usability. 
In  the  case  of  a  subscription  service,  this  figure  should  then  multiplied  by  the 
duration  of  the  problem  (reported  in  M17),  to  account  for  the  duration  of  the 
loss of the subscription service. 

2)  Over-/extra charges or hidden fees incurred by the consumer as a result of the 

problem can be directly used as specified by the respondent in M7. 

3)  Costs  incurred  by  the  consumer  trying  to  sort  out  the  problem  can  be 
calculated  as  the  sum  of  the  a)  costs  of  repairs  or  replacement/alternative 
goods/services,37  b)  costs  relating  to  court  proceedings  (if  such  costs  are 
presented  as  a  separate  item  in  the  questionnaire)  and  c)  other  costs  (as 
specified by the respondent in M12). 

Pre-redress financial detriment is calculated by summing elements 1, 2 and 3. 

Subsequently, substantial redress involves the following elements, again calculated 
separately for each respondent: 

4)  Monetary  redress  received  by  the  consumer  from  the  trader  (as  specified  by 

the respondent in M15). 

35  As  indicated  before  (see  footnote  98),  the  methodology  is  based  on  a  consumer  survey  targeting  the 
overall  population  without  pre-screening.  For  pre-screened  samples,  e.g.  in  the  context  of  single  market 
assessments, the calculation of incidence has to be adapted accordingly.   

36  This  approach was employed  in  the  consumer  detriment  study.  More  details  on  the  approach  applied  in 
this study are provided in Section 4.9. of the final report. 

37 In case the respondent repaired or replaced the good at his or her own expense, the reduction of value is 
not  considered  in  the  calculation,  as  the  related  repair  or  replacement  costs  constitute  the  detriment 
incurred, to avoid double counting. 

49 

 
 
                                                 
Study on measuring consumer detriment in the European Union 

5)  Value  of  any  repairs  or  replacement  by  the  trader.  In  the  case  a  good  is 
repaired  or  replaced  by  the  trader  (as  specified  by  the  respondent  in  M14), 
then  the  consumer  can  be  considered  to  be  reimbursed  for  any  reduction  in 
value  suffered  (i.e.  the  amount  of  reduction  in  value  calculated  in  element  1 
can be considered to be the value of the repairs/replacement); 

Substantial redress is calculated by summing elements 4 and 5. Finally, post-redress financial 
detriment is equal to pre-redress financial detriment (1+2+3) minus substantial redress (4+5). 

An  overview  of  the  data  sources  from  the  consumer  survey  for  the  step-by-step 
assessment of financial detriment is presented in the table below. 

50 

 
 
Study on measuring consumer detriment in the European Union 

Table 15: Consumer survey questions used to calculate the different elements of financial detriment 

1 

2 

3 

1+2+3 

4 

5 

4+5 

Q. 

Question topic 

Relevance for the 
six markets 
assessed in the 
consumer 
detriment study 

M3 

M7 

M8 

M9 

Amount paid or reference 
amount for good/service 

Over-/extra charges or 
hidden fees 

Usability of the good or 
service 

Actions taken by the 
consumer 

All six markets except 
loans, credit and credit 
cards 

All six markets 

All six markets except 
loans, credit and credit 
cards 

All six markets 

M12  Money spent trying to sort 
out the problem 

All six markets 

M14 

M15 

Actions taken by the trader  All six markets 

Amount received as 
reimbursement/ 
compensation 

All six markets 

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M17 

Duration of the problem 

Subscription services 1 

√ 

Source: Civic Consulting. √=indicates that the question contributes to the respective element mentioned in the table column headings. 1) Note: Subscription services are defined as services provided 
to the consumer on a continuous basis in exchange for a regular payment (e.g. mobile telephone service, electricity, internet, etc.). ‘Loss of service’ relates specifically to the loss of a subscription 
service. 

51 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study on measuring consumer detriment in the European Union 

Three  examples  of  the  calculation  of  financial  detriment  are  provided  below  for 
illustration purposes, using cases from the consumer detriment study. 38 

Goods market 

In the market for clothing, footwear and bags, one respondent experienced a problem 
with  women’s  footwear  that  had  cost  EUR  40.  The  problem  was  described  as  ‘item 
delivered  late’,  which  did  not  involve  over-/extra  charges  or  hidden  fees.  The 
respondent  indicated  that  the  item  could  be  used  ‘partly,  with  minor  difficulty’.  The 
respondent  made  a  complaint  to  the  seller,  and  did  not  incur  costs  to  sort  out  the 
problem. The trader did nothing as a response. 

The calculation of pre-redress financial detriment involves the following elements: 

•  Reduction in  value  relating  to loss  in usability of  the  good  (using  the price 

and the value assigned for usability39) = 40 * 0.33 = EUR 13.2; 

•  Over-/extra charges or hidden fees = EUR 0; 

•  Costs incurred by the consumer trying to sort out the problem: 

-  Costs of repairs or replacement good = EUR 0; 
-  Costs relating to court proceedings = EUR 0; 
-  Other costs = EUR 0. 

Pre-redress financial detriment is the sum of the elements above = EUR 13.2. 

Subsequently,  substantial  redress  is  EUR  0  in  this  case  as  the  respondent  indicated 
that the trader did nothing. 

Finally,  post-redress  financial  detriment  is  equal  to  pre-redress  financial  detriment 
minus substantial redress = 13.2 – 0 = EUR 13.2. 

Subscription services market 

In  the  market  for  mobile  telephone  services,  one  respondent  experienced  a  problem 
with  a  mobile  telephone  subscription  including  mobile  Internet  that  cost  EUR  25  per 
month.  The  problem  was  described  as  ‘poor  customer  service  of  after  sale  service’, 
‘unclear  or  complex  tariffs’,  ‘misleading  or  incorrect  indication  of  price’,  and  ‘was 
provided  (other)  services  I  did  not  request’.  The  respondent  indicated  that  s/he  paid 
EUR  10  in  over-/extra  charges  or  hidden  fees  and  that  the  service  could  be  used 
‘partly  with  major  difficulty’.  The  respondent  made  a  complaint  to  the  provider  and 
terminated the mobile telephone service contract. The respondent did not incur costs 
to  sort  out  the  problem.  The  provider  acknowledged  the  problem,  gave  an 
unsatisfactory explanation and gave a partial refund of EUR 5. The problem lasted one 
month to less than three months (i.e. a midpoint of two months). 

38  The  methodology  developed  to  calculate  financial  detriment  applies  to  each  problem,  irrespective  of 
whether  the  respondent  indicates  that  the  problem  is  his/her  most  serious  problem,  second  most  serious 
problem, or nth most serious problem. 

39 In the consumer detriment study, as detailed in Section 4.9.4. of the main report, an index value between 
0  and  1  was  assigned  to  usability  of  the  good  or  service  using  answers  to  question  M8  based  on  the 
following scale: ‘Not at all’: 1; ‘Partly, with major difficulty’: 0.67; ‘Partly, with minor difficulty’: 0.33; and 
‘Fully’: 0. 

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The calculation of pre-redress financial detriment involves the following elements: 

•  Loss of service relating to loss in usability of the service (using the monthly 
price,  the  value  assigned  for  usability40  and  the  duration  of  the  problem)  
= 25 * 0.67 * 2 = EUR 33.5; 

•  Over-/extra charges or hidden fees = EUR 10; 

•  Costs incurred by the consumer trying to sort out the problem: 

-  Costs of replacement services = EUR 0; 
-  Costs relating to court proceedings  = EUR 0; 
-  Other costs = EUR 0. 
financial 

detriment 

sum 

the 

of 

is 

Pre-redress 
= 33.5 + 10 = EUR 43.5. 

the 

elements 

above  

Subsequently, substantial redress involves the following element: 

•  Monetary redress received by the consumer from the provider = EUR 5. 

Finally,  post-redress  financial  detriment  is  equal  to  pre-redress  financial  detriment 
minus substantial redress = 43.5 – 5 = EUR 38.5. 

Other services market 

In  the  market  for  loans,  credit  and  credit  cards,  one  respondent  experienced  a 
problem  with  a  credit  card.  The  problem  was  described  as  ‘poor  customer  service  of 
after  sale  service’,  ‘unclear  or  complex  tariffs’,    ‘payments  charged  incorrect’  and 
‘fraudulent  use  of  credit  card’.  The  respondent  indicated  that  s/he  paid  EUR  500  in 
over-/extra  charges  or  hidden  fees.  The  respondent  spent  EUR  10  for  an  alternative 
banking  service  and  EUR  10  on  other  costs  to  sort  out  the  problem  (e.g.  telephone, 
postage, travel costs to sort out the problem, expert advice). The respondent made a 
complaint  to  the  credit  provider  and  asked  for  a  refund  of  the  money  paid.  The 
respondent  did  not  incur  other  costs  to  sort  out  the  problem.  The  credit  provider 
acknowledged  the  problem,  is  investigating  the  problem  and  gave  a  refund  of  the 
wrongly charged amount.  

The calculation of pre-redress financial detriment involves the following elements: 

•  Over-/extra charges or hidden fees = EUR 500; 

•  Costs incurred by the consumer trying to sort out the problem: 

-  Costs for an alternative service = EUR 10; 
-  Costs relating to court proceedings = EUR 0; 
-  Other costs = EUR 10. 
is 
financial 

detriment 

sum 

the 

of 

Pre-redress 
= 500 + 10 + 10 = EUR 520. 

the 

elements 

above  

Subsequently, substantial redress involves the following element: 

•  Monetary redress received by the consumer from the provider = EUR 500. 

Finally,  post-redress  financial  detriment  is  equal  to  pre-redress  financial  detriment 
minus substantial redress = 520 – 500 = EUR 20. 

40 See footnote 39. 

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3.2.2. Time loss41 

Assessing  the  detriment  from  time  loss  for  a  given  market  means  calculating  the 
average level of time loss per problem. However, as the data collected is in an ordinal 
format,  it  is  necessary  to  translate  each  response  into  a  quantitative  approximation. 
This  is  done  by  assigning  the  value  of  the  mid-point  of  the  ranges  to  each  answer 
item.  For  example,  ‘3  to  4  hours’  corresponds  to  3.5  hours,  ‘11  to  20  hours’ 
corresponds to 15.5 hours. In the consumer detriment study, a value of 20 hours was 
assigned to the category ‘More than 20 hours’, to safeguard a conservative estimate. 

Furthermore, as part of the assessment of detriment relating to time loss, the option 
of  monetising  the  hourly  time  loss  i.e.  placing  a  monetary  value  on  the  value  of  an 
hour lost due to a problem, can be considered in order to put detriment resulting from 
time loss  into  perspective  with  financial  detriment.  While  monetising time loss  allows 
for putting detriment resulting from time loss into perspective with financial detriment, 
it  may  impair  the  cross-country  comparability  of  time  loss  as  differences  in  average 
earnings between countries would entail potentially substantial differences in the value 
of  time  loss  between  countries.  In  the  consumer  detriment  study,  country-specific 
values of mean hourly earnings were applied based on Eurostat data42 and total time 
loss for each market assessed at EU level was monetised as part of the extrapolation 
(see step 3.5 below). 

3.2.3. Psychological detriment 43 

Psychological  detriment  can  also  be  a  major  factor  contributing  to  the  detriment  felt 
by  consumers.  Due  to  the  inherent  complexity  in  assigning  a  monetary  value  to 
different levels of emotional stress, psychological detriment should not be monetised. 
As an alternative, the magnitude of psychological detriment for a given market can be 
indicated by the percentage of respondents who felt either ‘quite a lot’ or ‘extremely’ 
emotionally stressed as a result of the problem they experienced (as was done in the 
consumer detriment study). 

3.2.4. Other forms of detriment 

In addition, adverse health effects (e.g. injuries) could be considered in the context of 
markets for which these dimensions would be specifically relevant. 44 

Social  detriment,  which  is  another  form  of  non-financial  detriment  that  may  result 
from  outcomes  related  to  purchases  or  transactions  that  did  not  meet  consumers’ 
expectations,  such  as  a  lack  of  trust  in  others  that  may  result  from  fraudulent 
practices,  could  also  be  considered.  In  the  context  of  the  consumer  detriment  study, 
social  detriment  was  considered  at  the  first  expert  workshop;  however,  it  was 
excluded  due  to  concerns  about  the  numbers  of  questions  that  would  be  needed  to 

41 For a more detailed description of the approach to data collection on time loss and to assessing detriment 
related to time loss, please refer to Section 4.9.5. of the consumer detriment study. 

42 Eurostat data series earn_ses_hourly  

43  For  a  more  detailed  description  of  the  approach  to  data  collection  on  psychological  detriment  and  to 
assessing  psychological  detriment,  please  refer  to  Section  4.9.6.  of  the  final  report  of  the  study  on 
measuring consumer detriment in the European Union. 

44  E.g.  food  markets.  Examples  of  relevant  questions  for  assessing  adverse  health  effects  are  provided  in 
Europe Economics, An Analysis of the Issue of Consumer Detriment and the Most Appropriate Methodologies 
to  Estimate  It,  London,  2007  and  Ipsos  MRBI  /  Competition  and  Consumer  Protection  Commission, 
Consumer Detriment Survey 2014, 2014 respectively.  

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obtain  data  of  high  quality  on  this  dimension  of  detriment  and  about  the  difficulty  of 
phrasing such questions. 

3.3. Context to the detriment measured 

Answers  to  contextual  questions  provide  further  information  on  the  context  in  which 
the  detriment  was  experienced,  which  allows  for  a  more  refined  analysis  of  results. 
The data on contextual information can be used either as standalone information, e.g. 
to  show  the  breakdown  of  different  problem  types,  or  as  a  cross-tabulation  with  the 
questions on magnitude of detriment, e.g. to show the average time loss for problems 
experienced  by  consumers  who  purchased  the  product  online.  Answers  to  questions 
related  to  factors  associated  with/drivers  of  vulnerability  (e.g.  those  outlined  in  Step 
2.3),  also  allow  for  indications  as  to  differences  in  the  incidence,  nature  and 
magnitude  of  detriment  experienced  by  specific  vulnerable  consumer  groups  to  be 
analysed, if sample sizes are sufficient.45 Additional tailored contextual questions could 
be added to allow for more specific and/or granular analysis. For instance, research on 
purchases  made  cross-border  could  include  question(s)  on  the  number  of  purchases 
made cross-border in order to calculate the proportion of cross-purchases that led to a 
problem out of all cross-border purchases. 

3.4. Triangulate results of consumer survey with other data sources, if relevant 

Additional  data  collection  tools/sources  to  consider  for  the  purposes  of  triangulating 
the  results  of  consumer  survey  include  data  on  consumer  complaints  and/or  a 
complementary mystery shopping exercise. As indicated above,  consumer  complaints 
data  allow  for  comprehensive  triangulation  of  incidence  data  across  the  full  range  of 
problem  types  reported  in  the  consumer  survey.  In  contrast,  a  mystery  shopping 
exercise would focus on specific phases of the commercial transaction, e.g. on the pre-
contractual phase in a website review or on the conclusion of the contract in mystery 
shopping exercises that include the actual purchase of goods/services either in shops 
or  online.  In  the  context  of  the  consumer  detriment  study,  a  mystery  shopping 
exercise  based  on  the  review  of  traders’  websites  focused  on  the  identification  of 
issues  related  to  selected  unfair  commercial  practices  and  to  the  provision  of  pre-
contractual  information  that  potentially  could  cause  consumer  detriment.  This 
approach  should  primarily  be  considered  for  markets  in  which  consumer  problems 
related  to  advertising  and  provision  of  pre-contractual  information  are  a  major 
concern. 

When  employing  one  or  both  of  these  tools,  the  aim  of  the  triangulation  is  to  check 
the consistency of results of the consumer survey with the data provided by the other 
tools. For example, using complaints data, the recommended approach is to compare 
the  frequency  of  problems  reported  by  respondents  in  the  consumer  survey  with  the 
frequency  of  consumer  complaints  of  the  same  type  registered  in  the  European 
Commission harmonised complaints database. Such a comparison can be facilitated by 
designing the categorisation of problem types in the consumer survey questionnaire to 
reflect  the  structure  of  the  complaints  categories  in  the  complaints  database,  in 
particular  by  making  the  broader  problem  categories  in  M6  identical  to  the  level  1 
complaint categories of the European Commission harmonised complaints database. 46 
Data can either refer to a percentage of consumers reporting a specific problem type, 
a  percentage  of  complaints  relating  to  a  problem  category,  or  a  percentage  of 

45  Examples of  the  use of  the data  collected  on  contextual  information  are provided  in  Section  6.8. of  the 
consumer detriment  study. Contextual  questions  may  need  to  be  adapted  or  complemented  depending on 
the scope and specificities of the assessment. 

46  Further  details  on  the  approach  to  triangulation  employed  in  the  study  on  measuring  detriment  in  the 
European Union and related results are provided in Sections 5 and 7 of the consumer detriment study. 

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websites  on  which  potentially  problematic  practices  could  be  observed.  For 
comparison,  the  data  from  the  various  tools  are  converted  to  a  common  frequency 
scale.  

The  various  data  sources  are  then  compared  and  conclusions  drawn  in  terms  of 
consistency across the data sources.  

For  this  comparison,  the  following  decision  rule  can  be  applied:  if  the  qualitative 
frequency  assessments  for  a  given  problem  type/complaint  type/mystery  shopping 
issue  of  both  of  the  data  sources  under  consideration  match  (e.g.  both  the  problem 
type  in  the  consumer  survey  and  the  complaint  type  in  the  complaints  data  are 
considered  to  occur  ‘frequently’),  or  do  not  differ  by  more  than  one  category  (e.g. 
‘frequently’  for  one  data  source  and  ‘occasionally’  for  the  other),  the  sources  can  be 
considered to be 'consistent'. Otherwise, they are considered to be 'not consistent'. 

Other sources of information, such as literature and previous surveys and reports, can 
also  be  used  to  put  results  into  perspective.  These  may  include  market-specific  data 
on the penetration rate or the frequency of use of goods and services, e.g. the number 
of passenger-kilometres per inhabitant in rail passenger transport for train services. 

3.5. Extrapolate results to country or for the entire EU, if relevant 

Having  calculated  the  incidence  of  problems  and  the  average  financial  detriment  and 
time loss per problem in the sample for the market(s) subject to analysis, depending 
on the scope of the study, the financial detriment at country level and/or for the entire 
EU can be estimated.  

3.5.1. Country level 

To obtain an estimate of financial detriment at the country level, it is first necessary to 
multiply the average financial detriment per problem by the incidence  of problems in 
each  market  in  order  to  arrive  at  the  average  financial  detriment  per  capita  for  the 
population  in  that  market.  Second,  the  average  financial  detriment  per  capita  is 
multiplied  by  the  size  of  the  population  in  order  to  arrive  at  an  estimate  of  total 
financial detriment for the country. The same approach applies to time loss. 

3.5.2. EU level 

Where  appropriate,  results  obtained  for  sample  countries  can  be  used  to  extrapolate 
results  for  the  rest  of  the  EU,  in  order  to  arrive  at  an  overall  level  of  financial 
detriment and time loss. In this case, both incidence as well as magnitude of financial 
detriment and time loss have to be estimated in the rest of the EU, based on available 
data  (such  as  the  MMS  and  Eurostat  data).  The  following  main  steps  could  be 
considered:  

•  Estimate the incidence of detriment in the rest of the EU; 

•  Estimate the average magnitude of financial detriment per problem for the 

rest of the EU; 

•  Estimate the average time loss per problem for the rest of the EU; 

•  Calculate the total financial detriment and total time loss of the rest of the 

EU; 

•  Calculate the total financial detriment and time loss for the EU. 

The approach used in the consumer detriment study, in which the results obtained for 
the  sample  countries  were  used  to  extrapolate  results  for  the  rest  of  the  EU,  is 
described below.  

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Study on measuring consumer detriment in the European Union 

Incidence of detriment 

To  extrapolate  the  incidence  of  detriment  measured  for  the  sample  countries  to  the 
rest  of  the  EU,  a  weighting  factor  using  data  from  the  European  Commission  Market 
Monitoring  Survey  (MMS)  of  2015  was  applied.  The  European  Commission’s  Market 
Monitoring  Survey/Consumer  Markets  Scoreboard  collects  data  on  the  rate  of 
problems and the market penetration rate. Multiplying these two variables provides an 
estimate of the incidence rate of problems for the market. While this is only an indirect 
method  of  calculating  incidence,  and  the  MMS  uses  a  different  survey  methodology, 
this allows for obtaining a market-specific incidence rate of problems for each country 
in  the  EU.  A  population-weighted  average  of  the  sample  countries’  MMS  incidence 
rates  is  then  calculated,  as  well  as  of  the  rest  of  the  EU.  This  is  depicted  in  the 
equation  below,  which  applies  to  both  groups  of  countries,  i.e.  the  sample  countries 
and the rest of the EU: 

1

𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐

𝑃𝑃𝑃𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐 � 𝑃𝑃𝑃𝑃𝑃𝑃𝑃 𝑃𝑟𝑟𝑃𝑐,𝑚 × 𝐼𝑟𝑃𝑀𝑃𝑟 𝑃𝑃𝐼𝑃𝑟𝑃𝑟𝑟𝑝𝑃𝐼 𝑃𝑟𝑟𝑃𝑐,𝑚 × 𝑃𝑃𝑃𝑐

𝐼𝐼𝐼𝐼𝐼𝐼𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐,𝑚 =
Finally,  the  weighting  factor  is  calculated  as  the  ratio  of  the  population-weighted 
average  of  the  sample  countries’  MMS  incidence  rates  and  of  the  rest  of  the  EU  for 
each  market.  The  ratio  of  the  MMS  incidence  rates  for  the  sample  countries  and  the 
rest  of  the  EU  is  applied  to  the  incidence  rates  calculated  in  the  consumer  detriment 
study  in  both  modes  for  the  total  of  the  sample  countries.  This  is  depicted  in  the 
equation below: 

𝐼𝐼𝐼𝑝𝐼𝑃𝐼𝐼𝑃𝑐𝑐𝑐𝑐,𝑚 = 𝐼𝐼𝐼𝑝𝐼𝑃𝐼𝐼𝑃𝑐𝑠𝑚𝑠𝑠𝑐,𝑚 ×

Magnitude of financial detriment 

𝐼𝐼𝐼𝐼𝐼𝐼 𝑐𝑐𝑐𝑐,𝑚
𝐼𝐼𝐼𝐼𝐼𝐼 𝑐𝑠𝑚𝑠𝑠𝑐,𝑚

To  extrapolate  the  average  magnitude  of  financial  detriment  per  problem  calculated 
for  the  sample  countries  to  the  rest  of  the  EU,  a  weighting  factor  was  applied.  This 
weighting  factor  is  calculated  on  the  basis  of  market-specific  Eurostat  price  index 
data,47  as  financial  detriment  is  highly  correlated  with  the  price  of  a  good  or  service 
respondents  experienced  a  problem  with  (see  Section  6.3.4.  of  the  consumer 
detriment  study  on  the  correlation  analysis).  For  this  purpose,  first  the  ratio  of  the 
population-weighted average price index  of the sample countries and the population-
weighted  average  price  index  of  the  rest  of  the  EU  is  calculated  for  each  of  the  six 
markets. This ratio (or weighting factor) is then multiplied with the average magnitude 
of  detriment  in  the  sample  countries  to  estimate  the  magnitude  of  average  financial 
detriment per problem in the rest of the EU. 

This is depicted in the equation below: 

𝐴𝐴𝑃𝑃𝑟𝐴𝑃 𝐹𝐹 𝑃𝑃𝑃 𝑃𝑃𝑃𝑃𝑃𝑃𝑃𝑐𝑐𝑐𝑐,𝑚 = 𝐴𝐴𝑃𝑃𝑟𝐴𝑃 𝐹𝐹 𝑃𝑃𝑃 𝑃𝑃𝑃𝑃𝑃𝑃𝑃𝑐𝑠𝑚𝑠𝑠𝑐,𝑚 ×

Magnitude of time loss 

𝑃𝑃𝑝𝐼𝑃 𝑝𝐼𝐼𝑃𝑥𝑐𝑐𝑐𝑐,𝑚 𝑃𝑃𝑃𝑐𝑐𝑐𝑐

𝑃𝑃𝑝𝐼𝑃 𝑝𝐼𝐼𝑃𝑥𝑐𝑠𝑚𝑠𝑠𝑐,𝑚 𝑃𝑃𝑃

𝑐𝑠𝑚𝑠𝑠𝑐

⁄
⁄

In contrast, for magnitude of time loss, cross-country differences in time spent dealing 
with a problem are not highly correlated with differences in the price paid for the good 
or  service  respondents  experienced  a  problem  with.  Indeed,  as  shown  in  the  results 
for  time  loss,  average  time  loss  for  a  given  market  is  relatively  similar  across 

47 Eurostat data series prc_ppp_ind, 2014. The full Eurostat price index data is in Annex II. 

57 

 
 
 
 
 
 
 
                                                 
Study on measuring consumer detriment in the European Union 

countries. Moreover, considering that the sample countries and the rest of the EU both 
constitute relatively diverse groups of countries, average time loss per problem in the 
sample countries is used as a proxy for the average time loss per problem in the rest 
of the EU. 

This is depicted in the equation below: 

𝐴𝐴𝑃𝑃𝑟𝐴𝑃 𝑇𝑇 𝑃𝑃𝑃 𝑃𝑃𝑃𝑃𝑃𝑃𝑃𝑐𝑐𝑐𝑐,𝑚 = 𝐴𝐴𝑃𝑃𝑟𝐴𝑃 𝑇𝑇 𝑃𝑃𝑃 𝑃𝑃𝑃𝑃𝑃𝑃𝑃𝑐𝑠𝑚𝑠𝑠𝑐,𝑚

Total financial detriment and total time loss 

Total financial detriment and total time loss of the rest of the EU are then calculated in 
the  same  way  as  for  a  sample  country,  i.e.  by  multiplying  the  average  financial 
detriment/time loss per problem by the incidence rate and by the population of age 18 
and above.  

This is depicted in the equations below: 

𝑇𝑃𝑟𝑟𝑃 𝐹𝐹𝑐𝑐𝑐𝑐,𝑚 = 𝐴𝐴𝑃𝑃𝑟𝐴𝑃 𝐹𝐹 𝑃𝑃𝑃 𝑃𝑃𝑃𝑃𝑃𝑃𝑃𝑐𝑐𝑐𝑐,𝑚 × 𝐼𝐼𝐼𝑝𝐼𝑃𝐼𝐼𝑃 𝑐𝑐𝑐𝑐,𝑚 × 𝑃𝑃𝑃 𝑐𝑐𝑐𝑐

𝑇𝑃𝑟𝑟𝑃 𝑇𝑇𝑐𝑐𝑐𝑐,𝑚 = 𝐴𝐴𝑃𝑃𝑟𝐴𝑃 𝑇𝑇 𝑃𝑃𝑃 𝑃𝑃𝑃𝑃𝑃𝑃𝑃𝑐𝑐𝑐𝑐,𝑚 × 𝐼𝐼𝐼𝑝𝐼𝑃𝐼𝐼𝑃 𝑐𝑐𝑐𝑐,𝑚 × 𝑃𝑃𝑃𝑐𝑐𝑐𝑐
Total financial detriment and time loss for the EU28 is then calculated by summing the 
values calculated for the sample countries and the rest of the EU.  

This is depicted in the equations below: 

𝑇𝑃𝑟𝑟𝑃 𝐹𝐹 𝐴𝑠𝑠,𝑚 = 𝑇𝑃𝑟𝑟𝑃 𝐹𝐹𝑐𝑐𝑐𝑐 𝐸𝐸,𝑚 + 𝑇𝑃𝑟𝑟𝑃 𝐹𝐹𝑐𝑠𝑚𝑠𝑠𝑐,𝑚

𝑇𝑃𝑟𝑟𝑃 𝑇𝑇 𝐴𝑠𝑠,𝑚 = 𝑇𝑃𝑟𝑟𝑃 𝑇𝑇𝑐𝑐𝑐𝑐 𝐸𝐸,𝑚 + 𝑇𝑃𝑟𝑟𝑃 𝑇𝑇𝑐𝑠𝑚𝑠𝑠𝑐,𝑚

Finally,  in  order  to  put  detriment  resulting  from  time  loss  into  perspective  with 
financial detriment, time loss at the EU level is monetised using a population-weighted 
mean hourly earnings rate for the EU in Euro, derived from Eurostat data on country-
specific mean hourly earnings.48 

This is depicted in the equation below: 

𝐼𝑃𝐼𝑃𝑟𝑝𝑀𝑃𝐼 𝑟𝑃𝑟𝑟𝑃 𝑇𝑇 𝐴𝑠𝑠,𝑚 = 𝑇𝑃𝑟𝑟𝑃 𝑇𝑇 𝐴𝑠𝑠,𝑚 ×

1

𝑃𝑃𝑃𝐴𝑠𝑠 � 𝐼𝑃𝑟𝐼 ℎ𝑃𝑜𝑃𝑃𝑜 𝑃𝑟𝑃𝐼𝑝𝐼𝐴𝑀𝑐,𝑚 × 𝑃𝑃𝑃𝑐

𝐴𝑠𝑠

48  See  Section 4.9.10.  of  the  consumer  detriment  study. In the  consumer  detriment  study,  hourly  earning 
rates  calculated  in  actual  Euro  were  used,  for simplicity  and  as  the  results  obtained  with  the  two  kinds of 
rates  were  similar.  Purchasing  power  parities  (PPPs)  take  into  account  price  level  differences  across 
countries.  They  indicate  how  many  currency  units  a  particular  quantity  of  goods  and  services  costs  in 
different  countries.  PPPs  can  be  used  as  currency  conversion  rates  to  convert  expenditures  expressed  in 
national currencies into an artificial common currency defined by Eurostat, the Purchasing Power Standard 
or PPS, thus eliminating the effect of price level differences across countries.  

58 

 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
Study on measuring consumer detriment in the European Union 

59 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study on measuring consumer detriment in the European Union 

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doi: 10.2818/815773