COMMISSION STAFF WORKING DOCUMENT Accompanying the document REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS on the mid-term evaluation of the Consumer Programme 2014-2020
Date: 2019-11-07
Institutions: Directorate-General for Justice and Consumers, European Commission
Subjects: EU programme, administrative cooperation, consumer information, consumer law, consumer movement, consumer policy, product safety, single market

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 7.11.2019  SWD(2019) 382 final  COMMISSION STAFF WORKING DOCUMENT Accompanying the document REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS   on the mid-term evaluation of the Consumer Programme 2014-2020  {COM(2019) 490 final}  
 
 
Table of contents 

1. 

INTRODUCTION ............................................................................................................................... 4 

1.1.  PURPOSE OF THE EVALUATION ................................................................................................ 4 

1.2.  SCOPE OF THE EVALUATION ..................................................................................................... 4 

2. 

BACKGROUND TO THE INTERVENTION ................................................................................. 5 

2.1.  POLICY CONTEXT .......................................................................................................................... 5 

2.2.  DESCRIPTION OF THE INTERVENTION AND ITS OBJECTIVES ........................................ 6 

2.3.  BASELINE AND POINTS OF COMPARISON .............................................................................. 9 

3. 

IMPLEMENTATION / STATE OF PLAY .................................................................................... 10 

3.1.  PROGRAMME MANAGEMENT .................................................................................................. 10 

3.2.  STATUS OF IMPLEMENTATION ................................................................................................ 11 

4.  METHODOLOGY ............................................................................................................................ 25 

4.1.  SHORT DESCRIPTION OF METHODOLOGY .......................................................................... 25 

4.2.  LIMITATIONS AND ROBUSTNESS OF FINDINGS ................................................................. 27 

5. 

 ANALYSIS AND ANSWERS TO THE EVALUATION QUESTIONS ..................................... 27 

5.1  EFFECTIVENESS ............................................................................................................................ 27 

5.2 

 EFFICIENCY ................................................................................................................................... 45 

5.3  RELEVANCE .................................................................................................................................... 54 

5.4  COHERENCE ................................................................................................................................... 55 

5.5  EU ADDED VALUE, COMPLEMENTARITY, SUSTAINABILITY ......................................... 57 

5.6  SIMPLIFICATION AND BURDEN REDUCTION ...................................................................... 61 

6.  CONCLUSIONS ............................................................................................................................... 63 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Glossary 

Term or acronym 

Meaning or definition 

ADR 

BEUC 

CHAFEA 

Alternative Dispute Resolution 

Bureau Européen des Unions de Consommateurs 

Consumers,  Health,  Agriculture  and  Food  Executive 
Agency  

CPC 

Consumer Protection Cooperation 

DG COMP 

Directorate-General Competition  

DG DIGIT 

Directorate-General Informatics 

DG ESTAT 

Directorate-General Eurostat - European statistics  

DG FISMA 

DG GROW 

DG JRC 

DG JUST 

Directorate-General  Financial  Stability,  Financial 
Services and Capital Markets Union 

Directorate-General 
Entrepreneurship and SMEs 

Internal  Market, 

Industry, 

Directorate-General Joint Research Centre 

Directorate-General Justice and Consumers 

DG SANTE 

Directorate-General Health and Food Safety 

DG TAXUD 

Directorate-General Taxation and Customs Union 

European Consumer Consultative Group 

European Economic Area 

European Free Trade Association 

Gross Domestic Product 

ECCG 

EEA 

EFTA 

GDP 

2 

 
Multiannual Financial Framework 

Online Dispute Resolution 

Non-governmental organizations 

Rapid Alert System for dangerous non-food products 

The  Commission's  Regulatory  Fitness  and  Performance 
programme 

Small and medium-sized enterprises 

Treaty on the Functioning of the European Union 

MFF 

ODR 

NGOs  

RAPEX 

REFIT 

SMEs 

TFEU 

3 

 
1. 

INTRODUCTION 

1.1. 

PURPOSE OF THE EVALUATION 

The  present  evaluation  covers  the  mid-term  evaluation  of  the  Consumer  Programme 
2014-2020.  The  legal  act  establishing  the  Consumer  Programme  contains  a  legal 
obligation to perform an evaluation1.   

The Consumer Programme 2014-2020 builds on and continues the actions funded under 
the  Consumer  Programme  2007-2013.  The  most  successful  elements  of  the  previous 
Programme  have  been  maintained  in  the  new  Programme.  The  results  of  the  mid-term 
evaluation fed into the design of the post-2020 Multi-annual Financial Framework. 

The  purpose  of  the  mid-term  evaluation  of  the  Consumer  Programme  2014-2020  is  to 
review  the  achievement  of  the  objectives  of  all  the  measures  (at  the  level  of  outputs, 
results  and  impacts,  the  latter  to  the  extent  possible),  the  state  of  play  regarding  the 
implementation of the eligible actions set out in Article 4 and the specific actions referred 
to in Annex I of the Regulation, the allocation of funds to the beneficiaries, the efficiency 
of  the  use  of  resources  and  the  programme's  European  added  value,  taking  into 
consideration  developments  in  the  area  of  consumer  protection  and  other  consumer-
relevant  EU  policies,  with  a  view  to  a  decision  on  the  renewal,  modification  or 
suspension of the actions.  

The  evaluation  addresses  the  scope  for  simplification,  the  programme's  internal  and 
external  coherence  including  possible  synergies/complementarities  with  other  EU 
programmes, the continued relevance of all objectives, as well as the contribution of the 
measures to the Union priorities of smart, sustainable and inclusive growth. The longer-
term impacts and the sustainability of effects of the programme have been evaluated to 
the  extent  feasible  given  that  the  programme  is  still  being  implemented  with  a  view  to 
feeding into a decision on a possible renewal, modification or suspension of a subsequent 
programme in terms of scope, nature and cost. 

1.2. 

SCOPE OF THE EVALUATION 

The evaluation reviews the state of play regarding the implementation of all the measures 
and their effects at the level of outputs, results and impacts and of the eligible actions set 
out in Article 4 and the specific actions referred to in Annex I of the Regulation.2 

The evaluation considers the implementation of the Programme in all EU Member States 
(taking account of the date of accession), as well as in Norway and Iceland. 

The  evaluation  period  is  the  period  covered  from  2014  until  2017.  While  some  of  the 
actions  committed  at  the  end  of  the  period  are  also  included  in  the  evaluation  for 

1 The mid-term evaluation of the Consumer Programme 2014-2020 is a legal obligation according to 
Article 13(2) of Regulation (EU) No 254/2014 on a multiannual Consumer Programme for the years 2014-
2020. According to this Regulation, by 30 September 2017, the Commission shall submit the evaluation 
report on the review undertaken to the European Parliament and the Council. 
2 Due to the timing of the 2014-2020 mid-term evaluation, some final deliverables or data, in particular for 
the legal commitments signed in 2016 and 2017, were not available at the time of evaluation. 
4 

 
 
                                                           
budgetary  purposes,  they  are  not  taken  into  the  consideration  for  the  evaluation 
questions.  

This evaluation covers some aspects related to the management of actions carried out by 
the  Consumers,  Health,  Agriculture  and  Food  Executive  Agency,  (hereafter  referred  as 
"CHAFEA").  Such  management  of  actions  have  only  been  taken  into  account  to  the 
extent that they may be relevant for the evaluation of the financial programme as defined 
by the evaluation questions, in particular with regards to the efficiency and effectiveness, 
and scope for simplification aspects.3  

2.  BACKGROUND TO THE INTERVENTION 

2.1. 

POLICY CONTEXT 

Article 169 of the Treaty on the Functioning of the European Union requires the EU to 
contribute to  protecting the health, safety  and economic interests of consumers through 
actions  in  the  field  of  consumer  protection  and  also  to  take  consumer  protection 
requirements  into  account  in  defining  and  implementing  other  Union  policies  and 
activities.  This  can  be  achieved  as  a  part  of  the  efforts  to  build  a  proper  functioning 
internal  market  in  which  both  consumers  and  business  benefit  equally.  In  addition,  the 
EU  may  adopt  measures  to  support,  supplement  and  monitor  the  policy  pursued  at 
national  level  to  promote  consumers'  rights  to  information,  education  and  to  organise 
themselves.  

With  consumer  spending  accounting  for  56%  of  the  EU  GDP,  consumers  can  play  a 
crucial role in achieving the EU goals of stimulating economic growth, employment and 
competition.  The  overarching  objective  of  consumer  policy  is  therefore  to  empower 
Europe's  500  million  consumers  by  providing  them  with  the  tools  necessary  for  their 
active  participation  in  the  market,  by  making  products  and  services  markets  work  for 
them, by facilitating the exercise of their power of choice and ensuring that their rights 
are properly enforced. 

Against this background, the EU has put in place over the past 60 years a set of consumer 
rights  and  policies  that  aim  to  achieve  this  objective,  either  through  horizontal 
instruments  or  sector-specific  legislation.  Recent  efforts  to  keep  this  framework  up-to-
date and fit to address evolving markets include the review of the Consumer Protection 
Cooperation  Regulation4  as  well  as  the  REFIT/Fitness  Check5  of  Consumer  and 

3  The  work  and  management  of  the  agency  per  se  are  not  in  the  scope  of  the  evaluation,  but  they  are 
subject to a separate evaluation exercise. 
4 Regulation  (EU)  2017/2394  of the  European  Parliament  and of the  Council of  12  December  2017     
on        cooperation        between        national        authorities        responsible        for        the        enforcement        of    
consumer protection  laws  and  repealing  Regulation  (EC)  No  2006/2004. 
5  Results  of  the  Fitness  Check  of  consumer  and  marketing  law  and  of  the  evaluation  of  the  Consumer 
Rights Directive: http://ec.europa.eu/newsroom/just/item-detail.cfm?item_id=59332  

5 

 
 
 
 
                                                           
Marketing  Law,  which  led  to  the  adoption  in  April  2018  of  the  New  Deal  for 
Consumers6.   

To implement its consumer policies, the European Commission set out its strategic vision 
for an EU consumer policy during the reference period of the evaluation in the Consumer 
Policy Strategy for the years 2007 – 20137 and later in the European Consumer Agenda8 
adopted  in  2012.  Under  the  current  Commission,  the  Juncker  Commission's  Priorities 
provide a framework for the EU consumer policy, in particular the following priorities: 
(1) “A Connected Digital Single Market”; (2) “A Deeper and Fairer Internal Market with 
a  Strengthened  Industrial  Base”  and  (3)"A  Resilient  Energy  Union  with  a  Forward-
Looking  Climate  Change  Policy".  These  documents  lay  down  the  policy  priorities  to 
support consumers' interests.  

For the period covered by this evaluation, the practical realisation of these priorities was 
underpinned by funding from the EU budget granted through the multi-annual Consumer 
Programme 2014-2020.  

2.2.  DESCRIPTION OF THE INTERVENTION AND ITS OBJECTIVES 

The  Consumer  Programme  2014-2020  with  an  amount  of  EUR  188.8  million  for  the 
years  2014-2020  was  established  by  Regulation  (EU)  No  254/2014  of  the  European 
Parliament  and  of  the  Council  of  26  February  20149.  It  was  adopted  to  support  the 
implementation  of  the  policy  priorities  set  out  in  the  European  Consumer  Agenda  - 
Boosting Confidence and Growth.  

This  programme  aims  to  help  citizens  fully  enjoy  their  consumer  rights  and  actively 
participate  in  the  Single  Market,  thus  supporting  growth,  innovation  and  meeting  the 
objectives  of  Europe  2020.  In  particular,  actions  funded  under  the  Programme  seek  to 
address issues linked to globalisation, digitalisation, the growing level of complexity of 
decisions  that  consumers  have  to  make,  the  need  to  move  towards  more  sustainable 
patterns of consumption, population ageing, social exclusion and the issue of vulnerable 
consumers.  

The programme builds on the actions funded under the previous programme covering the 
period  2007-2013.  It  ensures  a  smooth  transition  and  a  continuation  of  the  multiannual 
measures while taking into account the mid-term evaluation of the previous programme’s 
successes and areas requiring more attention.  

By and large the actions to be financed under the Consumer Programme 2014-2020 show 
a large degree of continuity with the previous programme. They have however been re-
organised under  four key  objectives  (as opposed to  two broader objectives focusing on 
consumer  protection  and  effective  application  of  consumer  protection  rules  under  the 

6 http://ec.europa.eu/newsroom/just/item-detail.cfm?item_id=620435  
7 COM/2007/0099 
8 COM(2012) 225 
9 http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32014R0254&from=EN  

6 

 
 
 
 
                                                           
previous  programme)  with  a  view  to  reflect  the  main  priorities  of  the  2012  Consumer 
Agenda and notably a stronger focus on access to redress and enforcement, as follows:   

1. 

2. 

3. 

4. 

Objective I — Safety: to consolidate and enhance product safety through effective 
market surveillance throughout the Union. 
Objective  II  —  Consumer  information  and  education,  and  support  to  consumer 
organisations:  to  improve  consumers’  education,  information  and  awareness  of 
their  rights,  to  develop  the  evidence  base  for  consumer  policy  and  to  provide 
support  to  consumer  organisations,  including  taking  into  account  the  specific 
needs of vulnerable consumers. 
Objective III — Rights and redress: to develop and reinforce consumer rights in 
particular  through  smart  regulatory  action  and  improving  access  to  simple, 
efficient, expedient and low-cost redress including alternative dispute resolution. 
Objective  IV  —  Enforcement:  to  support  enforcement  of  consumer  rights  by 
strengthening  cooperation  between  national  enforcement  bodies  and  by 
supporting consumers with advice. 

Only  two  actions  of  the  Consumer  Programme  2007-2013  do  not  feature  in  the 
Consumer  Programme  2014-2020,  namely  the  financial  contribution  to  ANEC,  which 
represents consumer interests in standardisation, and was transferred to Regulation (EU) 
No. 2015/201210 at the end of the 2007-2013 Consumer Programme and is now under the 
administration  of  DG  GROW  and  the  Financial  contributions  for  the  development  of 
integrated European Master Degree courses in  consumer issues which were intended to 
provide  initial  support  for  the  selected  academic  consortia  and  were  explicitly  non-
renewable grants.11 

The  implementation  of  the  2014-2020  Consumer  Programme  also  takes  account  of  the 
guidance provided by the following Juncker Commission  priorities:  a deeper  and fairer 
internal  market,  a  connected  digital  single  market,  and  a  more  resilient  Energy  Union. 
Furthermore,  the  Programme  supports  the  consumer-relevant  policy  contribution  to 
Sustainable Consumption/Circular Economy initiatives planned in 2017, in particular in 
Plan.
the 

Economy 

Circular 

context 

Action 

EU 

the 

of 

10 Regulation (EU) No 2015/2012 of the European Parliament and of the Council of 25 October 2012 on 
European  standardisation,  amending  Council  Directives  89/686/EEC  and  93/15/EEC  and  Directives 
94/9/EC,  94/25/EC,  95/16/EC,  97/23/EC,  98/34/EC,  2004/22/EC,  2007/23/EC,  2009/23/EC  and 
2009/105/EC  of  the  European  Parliament  and  of  the  Council  and  repealing  Council  Decision  87/95/EEC 
and Decision No 1673/2006/EC of the European Parliament and of the Council 

11 European Commission/Ecorys UK, Evaluation of consumer education, information and capacity building 
actions: Final report (2011) (p.104) 

7 

 
 
 
 
                                                           
The intervention logic underpinning the Consumer Programme 2014-2020 can be found hereafter.  
Figure 1: Consumer Programme 2014-2020 – Intervention logic 

8 

 
 
 
 
 
The  programme  aims  to  achieve  the  above  described  objectives  by  providing  financial 
support  to  actions  that  support  and  complement  Member  States’  policy.  For  instance, 
while  the  enforcement  of  consumer  rights  is  the prerogative  of  national  authorities,  the 
programme  contributes  to  enhance  the  effectiveness  of  national  enforcement  by 
facilitating the cooperation between enforcement authorities in Member States.   

2.3.  BASELINE AND POINTS OF COMPARISON  

As  clarified  in  the  previous  section,  even  though  the  Consumer  Programme  2007-2013 
was  organised  around  two  broad  objectives  as  opposed  to  the  four  more  targeted 
objectives  of  the  current  programme,  both  programmes  aim  at  addressing  similar 
challenges  in  a  continuous  way.  As  such,  the  baseline  for  the  Consumer  Programme 
2014-2020 is the situation at the end of the Consumer Programme 2007-2013: 

-  As  regard  Objective  I  -  product  safety:  whilst  product  safety  was  not  a  self-standing 
objective under the previous programme, both the mid-term evaluation of the Consumer 
Programme  2007-2013  and  the  impact  assessment  of  the  Consumer  Programme  2014-
2020  highlighted  the  continued  existence  of  problems  in  the  area  of  product  safety. 
Product  safety became a stand-alone objective of the Consumer Programme 2014-2020 
notably  with  a  view  to  address  differences  in  the  enforcement  of  product  safety 
legislation between Member States as well as their difficulties in working together in the 
absence of a clear pan-European enforcement framework and against the background of 
the increasing globalisation of production chains and the rise of e-commerce.  

-  As  regard  Objective  II  -  Consumer  information,  education  and  support  to  consumer 
organisations: while actions covered by this objective under the current programme were 
spread  across the two  general  objectives of the Consumer Programme 2007-2013, both 
the  mid-term  evaluation  of  the  latter  programme  and  the  impact  assessment  of  the 
Consumer Programme 2014-2020 concluded that problems continued to exist in the area 
of consumer information, education and support to consumer organisations, justifying the 
need to keep the focus on these areas. The impact assessment of the current Programme 
also  noted  that  consumer  markets  monitoring  was  still  relatively  underdeveloped,  in 
particular with respect to the understanding of ‘actual’ consumer behaviour and decision-
making  processes12.  Uneven  capacity  between  consumer  organisations  in  different 
Member  States  was  also  noted  as  a  problem  in  the  impact  assessment  for  the  current 
Programme.  also  in  addition  it reported that less than half of EU consumers (44%)  felt 
‘confident,  knowledgeable, and protected’  as consumers13;  a situation confirmed by the 
2013  Consumer  Scoreboard14    and  a  2011  Consumer  Empowerment  Survey15.    The 
consumer  information  and  education  tools  funded  under  the  previous  Consumer 
Programme were also considered to be inadequate16.  

- As regard Objective III – Rights and redress: The mid-term evaluation of the Consumer 
Programme 2007-2013 and the impact assessment for the current Consumer Programme 
identified a number of continuing problems related to consumer rights and redress. Both 
noted that consumer rights were still inadequately protected, especially in a cross-border 

12 Impact assessment of the Consumer Programme 2014-2020, p. 13 
13 Impact assessment of the Consumer Programme 2014-2020, p. 14 
14 European Commission, Consumer conditions scoreboard 9th edition (2013) 
15 European Commission/TNS Opinion & Social, Special Eurobarometer 342: Consumer Empowerment (2011) 
16 European Commission, Consumer Policy: Ex-post and Mid-term Evaluations Final Report (2011), p. 173; Impact assessment of 
the Consumer Programme 2014-2020, p. 15; European Commission/Ecorys UK, Evaluation of Consumer Education, Information and 
Capacity Building Actions: Final Report (2011) 
9 

 
 
                                                           
context,  with  the  result  that  consumers  feel  less  confident  shopping  cross-border  than 
domestically.17  The  impact  assessment  for  the  current  Programme  noted  that  consumer 
awareness  about  means  of  redress  was  insufficient,  and  that  vulnerable  consumers 
(especially the less educated and the elderly) were particularly reluctant to seek redress, 
even though they are no less likely than the general population to experience problems.18 
The  mid-term  evaluation  of  the  Consumer  Programme  2007-2013  concluded  that 
additional steps had been taken between 2011 and 2013 to  address these  problems, i.e. 
the development of the Online Dispute Resolution (ODR) platform and the funding of a 
study  on  consumer  vulnerability,  but  that  the  problems  identified  above  remained 
relevant at the start of the Consumer Programme 2014-202019 justifying the need to keep 
the focus on these areas.  

-  As  regard  Objective  IV  –  enforcement:  The  mid-term  evaluation  of  the  Consumer 
Programme 2007-2013 and the impact assessment for the current Programme concluded 
that  problems  continued  to  exist  in  the  area  of  enforcement  of  consumer  rights, 
particularly  in  a  cross-border  context,  justifying  the  need  to  keep  on  focusing  on 
enforcement.  The  mid-term  evaluation  notably  highlighted  that  such  problems  of  poor 
enforcement  resulted  in  EU  consumers  being  less  effectively  protected  when  shopping 
cross-border  than  domestically,  especially  with  respect  to  online  sales.20  The  ECC-Net 
was  also  not  considered  to  be  reaching  its  full  potential  in  cross-border  enforcement, 
principally due to low awareness among consumers21. 

3. 

IMPLEMENTATION / STATE OF PLAY 

3.1. 

PROGRAMME MANAGEMENT  

The  programme  identifies  priorities  and  for  each  priority  the  type  of  actions  that  are 
eligible for funding22. These actions are listed in the respective legal act establishing the 
programme, notably in the annex.  

The programme has been implemented by means of annual work programmes adopted by 
the Commission with the assistance of an advisory Committee formed by representatives 
from  Member  States23.  Each  annual  work  programme  sets  out  the  actions  to  be 
undertaken in a given year, including the allocation of financial resources, as well as the 
selection and award criteria and criteria for the percentage of EU financial contributions. 
The actions have been implemented mainly by calls for tender and calls for proposals. 

The beneficiaries of the financial support are public bodies and private non-profit-making 
bodies  in  the  Member  States,  including  officials  responsible  for  enforcing  consumer 
protection legislation (e.g. exchanges of officials), or European  consumer organisations, 
higher education institutions, students or teachers. The Programme is monitored through 
a series of indicators set out in Annex II of the legal act establishing it. 

17 European Commission, Consumer Policy: Ex-post and Mid-term Evaluations Final Report (2011), p. 171-172; Impact assessment 
of the Consumer Programme 2014-2020, p. 15 
18 Impact assessment of the Consumer Programme 2014-2020, p. 16 
19 See section 7 and the conclusions of Part 2 of this study. 
20 European Commission, Consumer Policy: Ex-post and Mid-term Evaluations Final Report (2011), p. 115-116, 171-172 
21 Impact assessment of the Consumer Programme 2014-2020, p. 16 (fn 13) 
22 See Articles 2 and 6  of the 2007 -2013 Programme and Articles 4  and 9 of the 2014 – 2020 Programme 
23 The committee is an advisory committee as defined by Regulation (EU) No 182/2011 

10 

 
 
 
 
                                                           
Since  2008  an  important  part  of  the  multi-annual  programmes  is  implemented  by  an 
executive  agency  established  in  Luxembourg,  currently  referred  to  as  the  "Consumers, 
Health,  Agriculture  and  Food  Executive  Agency  (CHAFEA)"24.  For  each  annual  work 
programme, the Agency and Directorate-general for Justice and Consumers jointly agree 
what actions will be implemented by the agency.   

3.2. 

STATUS OF IMPLEMENTATION  

The implementation  of the Consumer Programme 2014  –  2020 is  ongoing:  most of the 
related  performance  indicators  expected  for  2014,  2015  and  2016  have  been  achieved. 
The 2014, 2015 and 2016 annual work programmes, with a budget of EUR 21.9 million, 
EUR 22.5 million and EUR 23.7 million respectively, were executed, with a final rate of 
implementation  of  98,3%,  99%  and  99,52%  respectively.  The  implementation  of  the 
work programmes proceeded as planned except that the absorption of the budget by the 
Member States was lower than expected and the unused budget has been channelled to 
awareness raising campaigns. 

Please  find  here  below  the  main  results  in  terms  of  implementation  activities  per 
objective. Further information is included in the section on the effectiveness criterion. 

Objective I 

In  the  table  below,  both  indicators  for  the  evaluation  period  2014-2017  for  Objective  I 
are presented. The percentage of RAPEX25 notifications entailing at least one reaction by 
other  Member  States  amounted  on  average  to  43%  in  the  2014-2017  period  (46%  in 
2017), thereby in  the last  year almost  reaching the target  set  for 2020. The  ratio of the 
number  of  reactions  to  the  number  of  serious  risk  notifications  already  reached  the 
envisaged target, with an average of 1.58 in the 2014-2017 period (1.66 in 2017). 

Table 1: Indicators defined in the Regulation26 for Objective I 

Rapid Alert System for dangerous non-food products (RAPEX) 

Indicators provided in 
Regulation 

According to Article 3(1)(a) the objective will be measured in particular through the 
activity and effectiveness of the EU rapid alert system for dangerous consumer 
products (RAPEX). 

As specified in Annex II of the Regulation, relevant indicators are: 

Indicator: 

Baseline 
(2010) 
provided in 
Regulation 

Target in 
Regulation  
(by 2020) 

Interim status 

% of RAPEX notifications 
entailing at least one reaction 

43% (843 
notifications) 

Increase of 
10% by 2020 

46% (2017)j) 

24 For more details on the executive agency please refer to : http://ec.europa.eu/chafea/about/about.html    
25  Article  12  of  the  General  Product  Safety  Directive  (2001/95/EC)  (GPSD)  establishes  the  European 
Rapid Alert System for dangerous products to ensure that information about dangerous products withdrawn 
from  the  market  and/or  recalled  from  consumers  anywhere  in  Europe  is  quickly  circulated  between 
Member States and the European Commission, so that appropriate action can be taken everywhere in the 
EU.  
26 Regulation (EU) No 254/2014 of the European Parliament and of the Council of 26 February 2014  – 
thereinafter ‘the Regulation’. 

11 

 
 
 
                                                           
(by other Member States) 

Ratio number of 
reactions/number of 
notifications (serious risks)* 

1.07 

[47.5%] 

Increase of 
15% by 2020 
[1.23] 

1.66 (2017)h) 

The  table  below  shows  that  interviewees  assessed  activities  under  the  previous 
Programme on average with 3.8, and activities under the current Programme with 3.9, a 
stable  assessment  with  a  slight  positive  trend.  In  both  Programs,  largely  the  same 
activities  were  funded  (except  the  E-Enforcement  Academy,  and  the  databases  on 
cosmetics, which were only funded under the current Programme).  

Table  2:  Overview  of  progress  made  during  evaluation  period  (stakeholder 
assessment of activities - Objective I) 

Indicator 

Effectiveness of activities 
funded under Objective I  
(on a scale of 1 to 5) 

Benefits achieved 
(on a scale of 1 to 5) 

Baseline  
(annual average  
2011-13) 

Evaluation period 
(annual average 
2014-17) 

Largely effective  
(3.8) a) 

Largely effective 
(3.9) 

Moderately 
achieved  
(3.1) a) 

Moderately  
achieved  
(3.3) 

Progress made 

O / +  
(slight positive 
trend) 

O / +  
(slight positive 
trend) 

++ = significant progress made; + = progress made; O = stable; – = negative trend. 
Notes: Averages calculated on basis of the available annual data.  
a) Baseline value for whole Programme period CP 2007-2013 ) 

Regarding  the  positive  assessment  by  stakeholders  per  activities  under  Objective  I,27 
Training  for  enforcement  officials  received  the  highest  average  rating  in  terms  of 
effectiveness (4.2) 28, followed by Networking and events (4.0), then in descending order 
the joint actions, exchange of officials, the EU database on cosmetics, and RAPEX (3,8), 
see below.  

Figure  1:  To  what  extent  have  these  activities  been  effective  in  consolidating  and  enhancing 
product  safety  through  market  surveillance  in  the  European  Union?  CP  2014-2020.  Average 
assessments on a scale of 1 (Not at all effective) to 5 (Very effective) 

27 For details, please see in section on effectiveness criterion. 
28 On a scale from 1 to 5, with 5 being the best mark possible.  

12 

 
 
 
                                                           
Source: Civic Consulting, stakeholder interviews, question 3. N=22, 55, 45, 26, 15, 70 (in the order of activities from 
top to bottom). Not included were interviewees who answered “don’t know” or who did not provide an assessment 
because they did not participate in or use the output of the listed activities.  

As  well  positive  is  the  perception  of  the  benefits  that  most  of  these  activities  have 
achieved  in  the  Member  States  with  better  information  on  unsafe  products  for 
enforcement authorities achieving the highest average score (of 4.0), followed by better 
trained enforcement officials (3.7), better cooperation with enforcement authorities (3.6), 
better  information  for  consumers  (3.5),  improved  market  surveillance  and  enforcement 
(3.4) and better information for businesses (3.4), see table below. 

Figure 2: Please assess to what extent these activities have achieved the 
following benefits in your country – CP 2014-2020.  

13 

4.24.03.93.83.83.812345Training for enforcement officials (E-EnforcementAcademy for product safety officials)Networking and events (e.g. Product Safety Week,Consumer Safety Network meetings)Joint cooperation and enforcement actions in thearea of non-food consumer product safetyExchange of safety enforcement officials (GPSD)EU databases on cosmetics (Cosmetic ingredientdatabase, Cosmetic Product Notification Portal)Rapid Alert System for dangerous non-foodproducts (RAPEX)4.03.73.63.53.43.43.02.72.512345Better information on unsafe non-food productsfor enforcement authoritiesBetter trained enforcement officialsBetter cooperation with enforcement authoritiesin other Member StatesBetter information on unsafe non-food productsfor consumersImproved market surveillance and enforcementof product safety legislationBetter information on unsafe non-food productsfor businessesReduction in the number of accidents related tounsafe productsBetter cooperation with enforcement authoritiesin third countriesReduction in the number of accidents related tounsafe services 
 
 
 
 
Source:  Civic  Consulting,  stakeholder  interviews,  question  4.  N=63,  45,  53,  71,  64,  47,  36,  53,  28  (in  the  order  of 
activities from top to bottom). Not included were interviewees who answered “don’t know” or who did not provide 
an assessment because they did not participate in or use the output of the listed activities.  

Objective 2 

The only target set for Objective II on consumer information and education that concerns 
the  European  Consumer  Complaints  Registration  System-ECCRS  has  been 
achieved,  and  even  surpassed.  The  indicator,  i.e.  the  number  of  complaint  bodies  and 
number of countries submitting complaint data to the complaint database increased from 
37  complaint  bodies  representing  13  countries  in  2014  to  73  complaint  bodies 
representing 20 countries in 2015. 29 

Table 3: Indicators provided in Annex II of the Regulation (Objective II) 

ECCRS and related support measures    

Indicators 
provided in 
Regulation30 

Indicator: 

Number of complaint bodies 
and number of countries 
submitting complaints to 
the ECCRS 

Baseline 
(2012) 
provided in 
Regulation: 

Target in 
Regulation  
(by 2020): 

Interim 
status: 
(2015)g) 

33 complaint 
bodies from 
7 countries  

70 complaint 
bodies from 
20 countries  

73 complaint 
bodies from 
20 countries  

Interviewees  considered  the  activities  funded  under  Objective  II  of  the  current 
Programme on average to be largely effective, as was already the case for the previous 
Programme. A slight downward trend is noted, but mostly due to the ECCRS, which is 
the only new activity under Objective II of the current Programme, and assessed lowest. 
This is illustrated in the figure below: 

29 DG JUST 2014, 2015 Activity Reports, including Annexes; see fact sheet CP2014-20 Action 6 (sources 
g, h) 
30  Annex  II  of  the  Regulation  (EU)  No  254/2014  of  26  February  2014  on  a  multiannual  Consumer 
Programme for the years 2014-20; see fact sheet CP2014-20 Action 6  

14 

 
 
 
 
                                                           
Table  4:  Overview  of  progress  made  during  evaluation  period  (stakeholder 
assessment of activities - Objective II) 

Indicator 

Effectiveness of activities 
funded under Objective II  
(on a scale of 1 to 5) 

Benefits achieved 
(on a scale of 1 to 5) 

Baseline  
(annual average  
2007-13)a) 

Evaluation period 
(annual average 
2014-17) 

Largely effective  
(3.8) 

Largely effective 
(3.7) 

Moderately 
achieved  
(3.2) 

Moderately  
achieved  
(3.2) 

Progress made 

– / O 
(slight negative 
trend)  

O  

++ = significant progress made; + = progress made; O = stable; – = negative trend. 
Notes: Averages calculated on basis of the available annual data.  
a)Assessment concerns the whole Programme period 2007-2013 

The activities that were considered to be the most effective in reaching Objective II were 
Support to EU-level consumer organisations (BEUC) (average rating of 4.2), Networking 
and  events  (4.0), 
the  Consumer  Champion  Programme  (3.9)  and  Consumer 
scoreboards/market studies (both 3.8). As mentioned above, the ECCRS has received the 
lowest average assessment (2.9) by stakeholders in terms of its effectiveness (i.e. slightly 
less than "moderately effective"), and second lowest (3.0) in terms of benefits achieved.31 

31  Illustration  of  the  reasons  of  such  an  assessment  are  provided  in  the  section  on  the  effectiveness 
criterion. 

15 

 
 
 
                                                           
Figure  3:  To  what  extent  have  these  activities  been  effective  in  improving 
consumer  education/information,  developing  the  evidence  base 
for 
consumer  policy  and  providing  support  to  consumer  organisations?  CP 
2014-2020.  Average  assessments  on  a  scale  of  1  (Not  at  all  effective)  to  5  (Very 
effective) 

Source: Civic Consulting, stakeholder interviews, question 6. N=51, 83, 36, 77, 76, 53, 39, 34 (in the order of activities 
from  top  to  bottom).  Not  included  were  interviewees  who  answered  “don’t  know”  or  who  did  not  provide  an 
assessment because they did not participate in or use the output of the listed activities.  

In  terms  of  benefits,  Improved  representation  of  consumer  interests  at  EU  level  and 
Better information on consumer markets and problems across the EU to benchmark the 
situation in my country with the situation in other Member States were rated, on average, 
with  the  highest  level  of  achievement  (3.6  and  3.5).  Improved  capacity  of  national 
consumer  organisations  was  ranked  the  lowest  in  terms  of  level  of  achievement 
(particularly among consumer organisations)32 with an average assessment of 2.8. These 
benefit  ratings  tally  with  assessments  made  regarding  effectiveness  –  notably  the  high 
average rating for support to BEUC is reflected in the high average rating of improved 
representation of consumer interest at the EU level, see Figure below: 

32  “Improved  capacity  of  national  consumer  organisations”  received  an  average  assessment  of  2.5  from 
consumer organisations. 

16 

4.24.03.93.83.83.43.32.912345Support to EU-level consumer organisations (BEUC)Networking and events (e.g. EU Presidency events,ECCG meetings)Capacity building for consumer organisations(Consumer Champion)Consumer scoreboards and surveys ( including theConsumer Conditions Scoreboard and ConsumerMarkets Scoreboard)Consumer market studies (e.g. on the sharingeconomy, on geo-blocking, on measuringconsumer detriment)EU consumer information/awareness raisingcampaigns (e.g. on taking out credit, on energyefficiency)EU consumer education resources (ConsumerClassroom)European Consumer Complaints RegistrationSystem and related support measures 
 
 
 
 
                                                           
Figure  4:  Please  assess  to  what  extent  these  activities  have  achieved  the 
following benefits in your country – CP 2014-2020. Average assessments on a 
scale of 1 (Not at all achieved) to 5 (Fully achieved) 

Source: Civic Consulting, stakeholder interviews, question 7. N=81, 93, 94, 78, 53, 77, 65. (in the order of activities 
from  top  to  bottom).  Not  included  were  interviewees  who  answered  “don’t  know”  or  who  did  not  provide  an 
assessment because they did not participate in or use the output of the listed activities.  

Objective III 

As  shown  by  the  table  below,  the  target  set  in  the  Regulation  regarding  the  number  of 
complaints registered on the ODR platform could be reached, despite the limited period 
of time that the platform has been  operational (since 2016): 

Table 5: Indicators provided in Annex II of the Regulation - ODR Platform 

Indicators 
provided in 
Regulation
33 

Indicator: 

Number of cases dealt 
with by a Union-wide 
online dispute resolution 
(ODR) system 

Baseline (2010) 
provided in 
Regulation: 

17 500 (complaints 
received by ECCs 
related to e-
commerce 
transactions)  

Target in 
Regulation  
(by 2020): 

100 000  

Interim 
status:  

55 002  

(2017) 

33  Annex  II  of  the  Regulation  (EU)  No  254/2014  of  26  February  2014  on  a  multiannual  Consumer 
Programme for the years 2014-20; see fact sheet CP2014-20 Action 9. 

17 

3.63.53.43.33.23.02.812345Improved representation of consumer interests at EUlevelBetter information on consumer markets and problemsacross the EU to benchmark the situation in my countrywith the situation in other Member StatesBetter information on consumer markets and problemsin my countryBetter information for consumers (e.g. when taking outcredit, or on energy efficiency)Better resources for teachers as a basis for consumereducation at schoolsBetter data on consumer complaints in other MemberStatesImproved capacity of national consumer organisations 
 
 
 
                                                           
Table  6:  Indicators  provided  in  Annex  II  of  the  Regulation  –  consumer 
action in response to a problem 

Indicators 
provided in 
Regulation 

Indicator: 

% of consumers who took 
action in response to a 
problem encountered in 
the past 12 months 

Baseline (2010) 
provided in 
Regulation: 

Target in 
Regulation  
(by 2020): 

83%  

90%  

Interim 
status:  

69%  

(2016) 

Despite  the  introduction  of  ADR  mechanism  and  ODR  platform,  the  percentage  of 
consumers  taking  action  (i.e.  complaining)  in  response  to  a  problem  encountered  has 
actually declined from the baseline level of 83% in 2010 to 69% in 2016.34 

Unresolved cases referred by ECCs to ADR bodies in 2016constituted 18%, as shown in 
the  table  below.  Although  this  proportion  represents  a  doubling  of  the  baseline  value 
provided in  2010 (9%),  the Regulation  target  of  75% by 2020 will not  be reached, if a 
similar trend remains. 

Table  7:  Indicators  provided  in  Annex  II  of  the  Regulation  –  cases  dealt 
with by the ECCs which were subsequently referred to ADR  

Indicators 
provided in 
Regulation 

Indicator: 

% of those cases dealt with by the ECCs 
and not resolved directly with traders 
which were subsequently referred to ADR 

Baseline (2010) 
provided in 
Regulation: 

Target in 
Regulation  
(by 2020): 

Interim 
status:  

9%  

75%  

18% 

(2016) 

Activities funded under Objective III in stakeholders' views were considered on average 
moderately effective under both Programmes (see table below).    

34 Note however that the wording and response options for this question in the Consumer Scoreboards was 
changed  substantively  between  2011  and  2012,  limiting  the  comparability  between  these  periods.  For 
further explanation see par. 3.2 implementation status under Objective II. 

18 

 
 
 
 
 
                                                           
Table  8:  Overview  of  progress  made  during  evaluation  period  (stakeholder 
assessment of activities – Objective III) 

Indicator 

Effectiveness of activities 
funded under Objective III 
(on a scale of 1 to 5) 

Benefits achieved 
(on a scale of 1 to 5) 

Baseline  
(annual average  
2011-13) 

Evaluation period 
(annual average 
2014-17) 

Progress made 

Moderately 
effective  
(3.4) a) 

Moderately 
achieved  
(3.2) a) 

Moderately effective  
(3.4) 

O  

Moderately achieved  
(3.1) 

O   

++ = significant progress made; + = progress made; O = stable; – = negative trend. 
Notes: Averages calculated on basis of the available annual data. a) Baseline value for whole Programme period CP 
2007-2013. ODR platform and communication campaigns on ADR/ODR were only funded under the 2014-2020 
Programme, so that these activities are not assessed regarding CP 2013-2020.  

Regarding  the  effectiveness  of  these  activities  in  developing  and  reinforcing  consumer 
rights  through  smart  regulatory  action  and  improving  access  to  simple  and  low-cost 
redress, see below:  

Source: Civic Consulting, stakeholder interviews, question 9. N=31, 76, 76, 53, 71, 85, 78 (in the order of 
activities from top to bottom). Not included were interviewees who answered “don’t know” or who did 
not provide an assessment because they did not participate in or use the output of the listed activities.  

19 

3.83.63.53.33.33.23.012345Citizens' Energy ForumNetworking and events (e.g. meetings of ODRcontact points, Financial Services Users Groupmeetings, working groups)Other EU consumer policy studies (e.g. evaluations, study on enforcement authorities’ powers in the application of CPC Regulation )Behavioural studies (e.g. on consumer decisionmaking in insurance services, on advertising marketpractices in online social media)Communication campaigns and actions onAlternative Dispute Resolution/ODRConsumer SummitOnline Dispute Resolution (ODR) Platform 
 
 
 
 
Figure 5: With regard interviewees' views on benefits achieved by activities 
in their country: 

Source: Civic Consulting, stakeholder interviews, question 10. N=84, 83, 87, 95, 91, 82, 89 (in the order of activities 
from  top  to  bottom).  Not  included  were  interviewees  who  answered  “don’t  know”  or  who  did  not  provide  an 
assessment because they did not participate in or use the output of the listed activities.  

It is interesting to note that consumers increasingly - from 39% in 2008 to 52% in 2016 -
consider it easier to settle disputes with traders through out-of-court bodies than through 
the courts35, indicating an improvement in the accessibility of ADR during the evaluation 
period (see below). 

35 See par 3.3 Status of Implemenation under Objective III 

20 

3.43.33.23.23.12.92.712345Smarter regulatory action at EU level in the field ofconsumer policyBetter cooperation/exchange of best practices withauthorities/stakeholders in other Member StatesBetter understanding of consumer decision making as abasis for consumer policyBetter information for consumers on ODR/ADRBetter information for traders on ODR/ADRBetter access for consumers in my country to ADR inother countries through ODR platformBetter access for consumers in my country to ADR in mycountry through ODR platform 
 
 
 
 
                                                           
Figure 6: Percentage of consumers who agree that it is easy to settle 
disputes with retailers and service providers through an out-of-court body 
or through the courts (EU average), 2008-2016 

Source:  Own  compilation  based  on  year-over-year  differences  indicated  in  the  Flash 
Eurobarometer 397 and the Commission’s 2016 survey of consumers’ attitudes toward cross-
border  trade  and  consumer  protection.  The  vertical  line  represents  the  beginning  of  the 
Consumer Programme 2014-2020. Question text: How strongly do you agree or disagree with 
each of the following statements. In (our country) … It is easy to settle disputes with retailers 
and service providers through an out-of-court body (i.e. arbitration, mediation or conciliation 
body)  /  It  is  easy  to  settle  disputes  with  retailers  and  service  providers  through  the  courts. 
Shown above are those who ‘Agree’ and ‘Strongly agree’ with these statements. 

Objective IV  
As  for  the  three  indicators  related  to  information  exchange  within  the  CPC  network36, 
two (information requests, and enforcement requests) showed a substantial increase from 
the 2011-2013 baseline period to the year 2017, whereas the third one on alerts remained 
stable  (see  below  Table  9).37  Requests  for  enforcement  measures  reached  in  2017  the 
highest number since the Network’s inception (198), meeting already the target for 2020. 
For  the  additional  indicators  of  the  timely  handling  of  information  and  enforcement 
requests38, the targets set in the Programme could be reached. 39   

36 See Commission Work Programme 2018 “An agenda for a more united, stronger and more democratic 
Europe", COM/2017/0650 final. 
37 Requests for enforcement measures reached in 2017 the highest number since the Network’s inception 
(198), meeting already the target for 2020. The 2017 number of alerts is still slightly below (but close to) 
the 2020 target 
38 According to the Operational Guidelines for coordinated enforcement within the CPC Network, requests 
for  information  should  be  handled  within  3  months  and  requests  for  enforcement  measures  within  9-12 
months. Impact Assessment 2016, p. 15. 
39 In the CPC Network, significant fluctuations in the types and numbers of request in different years can 
be  observed,  which  likely  depend  on  external  circumstances,  and  the  preferences  of  enforcement 
21 

0%10%20%30%40%50%60%70%80%90%100%2008200920102011201220142016Out-of-court bodiesCourts 
 
 
 
                                                           
The  final  two  indicators  in  the  Regulation  to  measure  achievement  of  Objective  IV 
concern the activity of the ECCs and how well known they are to consumers. The targets 
in  the  Regulation  in  this  respect  have  been  surpassed,  which  may  be  due  to  the 
exponential  growth  of  the  Internet  and  of  users’  access  to  online  services,  which 
contributes  to  an  increase  in  online  traffic  in  general,  and  also  in  cross-border  B2C 
transactions (as well as related problems).  

As  shown  in  the  above  table,  one  of  the  targets  for  2020  is  106 500  contacts  with 
consumers,  which  was  surpassed  already  in  2016.  It  can  be  projected  that  by  2020  the 
ECC-Net  will  reach  even  higher  volumes.  The  other  indicator  concerns  the  number  of 
visits  to  the websites.  The projected number of  website visits  in  2017 at  more than 8.5 
million is already three times the targeted number for 2020. It can be concluded that the 
targets  set  by the Consumer Programme for the  ECC-Net  have already been more than 
met. 

Table 9: Overview of progress made during evaluation period (indicators set 
in the Regulation – Objective IV) 

Indicator 

Number of 
requests to 
exchange 
information 
between CPC 
authorities 

Number of requests 
for enforcement 
measures between 
CPC authorities  

Number of alerts 
within the CPC 
Network  

% of enforcement 
requests handled 
within 12 months 
within the CPC 
Network 

Baseline  
(annual average  
2011-13)b) 

Evaluation period 
(annual average  
2014-17) 

Targets in 
Regulation 
(by 2020) 

Progress made 

80 

139 

58 

47% 

101 
(2017: 80) 

168 a) 

165 
(2017: 198) 

185 a) 

54 
(2017: 78) 

50% 
(2017: 24%) 

82 a) 

60% 

O / + 
(stable if only 
2017 is 
considered) 

++ 
(target already 
achieved in 
2017) 

+     
(target nearly 
achieved in 
2017) 
O / –   
(Negative 
trend, if only  
2017 
considered)    

authorities for particular types of requests. When considering the overall information flow on basis of the 
annualised averages, the total number of requests per year has overall increased by 16% (from the baseline 
value of 277 requests per year for the period 2011-2013 to a total of 320 requests per year during the 2014-
2017 period), which confirms an increasing information  flow through the  network and the trend towards 
achieving the related targets. 

22 

 
 
 
 
 
 
 
 
 
 
                                                                                                                                                                            
% of information 
requests handled 
within 3 months 
within the CPC 
Network 

Number of contacts 
with consumers 
handled by the ECCs 

Number of visits to 
the websites of the 
ECCs 

33% c) 

45% 
(2017: 23%) 

50% 

+ / – 
(Negative 
trend, if only  
2017 
considered)   

74 182 

99 756 
(2016: 111 563) 

106 500 a)  ++ 

2 335 000 d) 

5 579 663 
(2017: 8 542 936) 

2 839 000 a) 

(target already 
achieved in 
2016) 

++ 
(target already 
achieved) 

++ = significant progress made; + = progress made; O = stable; – = negative trend. 
Notes: Averages calculated on basis of the available annual data. a) In Annex II of the Regulation, this target is 
provided as a specified percentage increase compared to the baseline value provided therein. For convenience 
reasons, the table provides the target in absolute values, calculated on the basis of the Regulation baseline and the 
target set. b) Note that baseline data has been updated. The baseline used in the Regulation is mostly the annualised 
average 2007-2010 (see Part 2 of this report for the related data). c) Average 2007-2010, no data available for 2011-
2013. d) Average for years 2011 and 2013.  

Stakeholders considered the activities implemented in the first four  years of the current 
Consumer Programme under Objective IV to be largely effective, with a slight positive 
trend, when comparing them to the assessment of the 2007-2013 Programme.    

Table 10: Overview of progress made during evaluation period (stakeholder 
assessment of activities – Objective IV)  

Indicator 

Effectiveness of activities 
funded under Objective IV  
(on a scale of 1 to 5) 

Benefits achieved 
(on a scale of 1 to 5) 

Baseline  
(annual average  
2011-13) 

Evaluation period 
(annual average 
2014-17) 

Largely effective  
(3.7) a) 

Largely effective 
(3.8) 

Progress made 

O / +  
(slight positive 
trend) 

Moderately 
achieved  
(3.4) a) 

Largely achieved  
(3.6) 

+  

++ = significant progress made; + = progress made; O = stable; – = negative trend. 
Notes: Averages calculated on basis of the available annual data.  

The activities that were considered to be the most effective in contributing to Objective 
IV  were  Training  of  consumer  protection  enforcement  officials,  European  Consumer 
Centres  Network  and  Networking  and  events  (all  with  an  assessment  of  4.0).  Other 
activities were assessed slightly lower, but still as largely effective (with ratings between 
3.9 and 3.6), see Figure below:   

23 

 
 
 
 
Figure  7:  To  what  extent  have  these  activities  been  effective  in  supporting 
enforcement  of  consumer  rights  by  strengthening  cooperation  between 
national enforcement bodies and by supporting consumers with advice?  

Source:  Civic  Consulting,  stakeholder  interviews,  question  12.  N=26,  67,  73,  26,  43,  58,  55,  71  (in  the  order  of 
activities from top to bottom). Not included were interviewees who answered “don’t know” or who did not provide 
an assessment because they did not participate in or use the output of the listed activities.  

Regarding  the  perceived  benefits  of  the  specific  enforcement-related  activities  in  their 
own countries, the highest rated were Better advice for consumers in cross-border cases 
in the EU, Better training of ECC-staff and Other benefits. 

24 

4.04.04.03.93.93.73.63.612345Training for consumer protection enforcementofficials (E-Enforcement Academy)European Consumer Centres Network (ECC-Net)Networking and events (e.g. Consumer PolicyNetwork Group meetings, ECC-Net meetings)Exchange of enforcement officials (CPC)Training for ECC-NetEU-wide screening of websites (Sweeps)Joint actions for the enforcement of consumerprotection laws (CPC)Consumer Protection Cooperation (CPC) Network 
 
 
 
Table  11:  Overview  of  progress  made  during  evaluation  period  (indicators 
for potential wider effects – Objective IV) 

Baseline  
(annual average  
2011-13) 

Evaluation period 
(annual average 
2014-17) 

60% 

65% 

62% 

73% 

Progress made 

+  

+  

2012: 25% 

21% 

+   

75% 

66% 

– 

Indicator 

Percentage of consumers who 
trust public authorities to 
protect their rights as a 
consumer 

Percentage of consumers who 
agree that in general, retailers 
and service providers in their 
country respect the rules and 
regulations of consumer law 

Percentage of consumers who 
encountered at least one 
problem that they considered 
legitimate to complain about  
(Eurobarometer data) 

Percentage of retailers who 
agree that the public 
authorities actively monitor 
and ensure compliance with 
consumer legislation in their 
sector 

++ = significant progress made; + = progress made; O = stable; – = negative trend. 
Notes: Averages calculated on basis of the available annual data.  

4.  METHODOLOGY 

4.1. 

SHORT DESCRIPTION OF METHODOLOGY 

The  evaluation  was  carried  out  between  October  2017  and  April  2018.  The  evaluation 
was  supported  by  a  study  carried  out  by  an  external  contractor.  This  evaluation  also 
builds  on  the  mid-term  evaluation  of  the  Consumer  Programme  2007-2013  and  the 
Impact  Assessment  for  the  current  Programme,  notably  as  regards  the  definition  of  the 
baseline.  

For the purpose of this evaluation a broad range of reports, academic literature and other 
documentation on the actions and activities funded under the Consumer Programme were 
collected, reviewed and processed.  

To  ensure  a  coverage  of  interests  as  broad  as  possible,  a  wide  variety  of  stakeholders 
were  consulted  for  the  evaluation.  The  consultation  process  combined  targeted 

25 

 
 
 
 
 
consultation  of  stakeholders  through  interviews,  an  open  public  consultation  (in 
combination  with  the  broader  consultation  process  for  the  preparation  of  the  post  2020 
funding  programmes)  and  discussions  with  stakeholders  at  network  meetings  taking 
place during the period of the evaluation.  

182 interviews were conducted by the contractor with stakeholder organisations in all 28 
Member States, Norway and Iceland, and at the EU level. Stakeholder interviews covered 
ministries  in  charge  of  consumer  policy  or  consumer  agencies,  the  national  authorities 
responsible  for  enforcement  of  consumer  legislation  and  other  national  authorities 
responsible for policy and enforcement of relevant legislation, national representatives of 
the  Consumer  Safety  Network  (CSN)  or  RAPEX  contact  points,  national  consumer 
organisations  and  European  Consumer  Centres.  The  evaluation  team  also  contacted 
national  business  organisations  and  reached  out  to  relevant  EU  level  business 
organisations, as well as ANEC and BEUC, for interviews. 

A public consultation took place from 10 January 2018 until 9 March 2018 as part of a 
consultation on EU funds in the area of Investment, Research and Innovation, SMEs and 
Single Market preparing the post 2020 funding programmes. 

The evaluation team also participated in six meetings with relevant EU networks40 

Annex 2 of this document contains the results and uptake of all consultation activities.  

In  addition,  eight  case  studies  were  developed  focusing  on  four  specific  actions41  and 
cross-cutting activities42 financed by the Consumer Programme. The selection of action-
specific case studies was done on the basis of several criteria, including the need to cover 
all  Programme  objectives  and  to  look  into  these  key  actions  that  involve  considerable 
financial resources, which are essential for identification of main results and assess their 
effectiveness  and  which  have  not  yet  been  evaluated  separately.  In  addition,  the  case 
studies on cross-cutting activities were selected notably to cover specific policy areas, to 
identify  synergies/complementarities  with  other  EU  programmes  and  to  provide  key 
insights  for  addressing  specific  evaluation  questions  (for  instance  as  regards  the 
coherence of the Consumer Programme with other EU policies/priorities). 

Finally,  the  information  collected  from  the  various  sources  for  each  action  has  been 
consolidated and presented in fact sheets which are structured as follows: 

• 
• 
• 
• 

Specific objective and eligible actions; 
Description of activities; 
Amounts committed during Programme period; 
Specific activities funded during Programme period; 

40 European Consumer Consultative Group (ECCG) (twice), Consumer Financial Programme Committee 
(CFPC),  Consumer  Policy  Network  (CPN),  Financial  Services  User  Group  (FSUG)  and  Consumer 
Protection Cooperation Network (CPC) 
41  Coordination  of  market  surveillance  and  enforcement  actions  on  product  safety  (Action  2);  Capacity 
building  and  training:  for  consumer  organisations  (Consumer  Champion,  Action  5)  and  for  CPC/GPSD 
enforcement  officials  (E-Enforcement  Academy,  Actions  2  and  10);  Facilitating  access  to  ADR/ODR 
(Action 9); and Coordination of surveillance and enforcement actions with regard to Regulation (EC) No 
2006/2004 (Action 10). 
42  Digital  Single  Market;  Energy  consumers  and  sustainable  consumption;  Evidence  base  for  EU 
consumer policy; Convergence to a high level of consumer protection between different Member States. 

26 

 
 
 
                                                           
• 
• 
• 
• 

Outputs and results of activities; 
Excerpts from previous assessments/evaluations; 
Stakeholder assessment of the effectiveness of activities under the action;  
Key sources. 

4.2.  LIMITATIONS AND ROBUSTNESS OF FINDINGS 

At the moment of the evaluation, the majority of financed actions were still at the early 
stage of the implementation providing limited data on results of actions and impacts of 
the  programme.  Therefore  the  mid-term  evaluation  of  the  programme  mostly  relied  on 
stakeholder assessments on the implementation and outputs of actions financed under the 
Consumer Programmes.   

Where possible, findings from interviews were triangulated with quantitative analysis of 
outputs  and  actions.  To  the  extent  possible,  the  analysis  of  evaluation  questions  was 
informed  by  a  comparison  with  a  baseline  situation  (end  of  the  previous  programming 
period). 

5. ANALYSIS AND ANSWERS TO THE EVALUATION QUESTIONS 

5.1 EFFECTIVENESS 

Objective I Product safety 

Key findings43 

The  Consumer  Programme  2014-2020  has  made  substantial  progress  in  achieving 
Objective  I  compared  to  the  baseline  period.  Activities  have  contributed  to  improved 
information  exchange  and  cooperation  between  Member  States,  thereby  reducing 
differences in enforcement across the EU. 
The Rapid Alert System for dangerous non-food products-RAPEX44  has grown into an 
effective  and  important  pillar  of  the  EU  market  surveillance  architecture  that  is 
internationally  recognised  and  appreciated  by  its  main  target  groups  across  the  EU. 
Activities  to  support  EU  wide  market  surveillance  and  enforcement  measures,  such  as 
joint  actions, training and networking  are considered to  be effective by the main target 
group,  national  authorities.  They  lead  to  coordinated  approaches  to  common  problems, 
direct  contacts  between  authorities  from  different  countries  and  exchange  of  best 
practices.  They  also  support  Member  States'  authorities  in  addressing  new  challenges 
(e.g. through the E-Enforcement Academy). 

The activities implemented under the Programme have therefore been largely effective in 
consolidating  and  enhancing  product  safety  through  market  surveillance  in  the  EU, 
according to the results of the evaluation and in line with stakeholder assessments. The 
choice  of  actions  builds  upon  and  continues  previous  Consumer  Programmes,  and  is 
appropriate for achieving the Programme's Objective I.  

43 The « Key findings » per objective are taken from the main outcomes of the mid-term evaluation of the 
Consumer Programme 2014-2015. 
44 As presented in the fact sheets on the actions and the case studies conducted under the evaluation of the 
Consumer programme (PAG 199 & 296). 

27 

 
 
 
                                                           
Key factors that influence level of achievements related to the objective are limited staff 
and  financial  resources  for  market  surveillance  and  enforcement  in  Member  States,  as 
reported  by  interviewees.  Stakeholders  cited  the  continued  presence  of  unsafe  products 
on the market as well as emerging risks, e.g. from new, technically complex products or 
from  e-commerce  with  third  countries,  as  evidence  that  market  surveillance  needed  to 
continuously adapt to new challenges. 

While  consumer  and  retailer  perception  of  the  level  of  product  safety  and  enforcement 
depend on various factors, results from EU-wide surveys can provide some indication of 
potential  wider  effects  of  the  Programme  in  the  absence  of  more  objective  measures. 
Consumer trust in product safety has increased during the Programme period, in parallel 
to the efforts in enforcing product safety in recent years, both at national and EU levels. 
Also, roughly three quarters of retailers agree that public authorities actively monitor and 
ensure compliance with product safety legislation in their sector. Retailers' assessment of 
enforcement  activities  by  authorities  fell  somewhat  around  the  time  of  the  start  of  the 
Consumer Programme 2014-2020 and has remained stable since then. 

the  perception  of  stakeholders  regarding 

Overall 
the  effectiveness  of  actions 
implemented  in  the  first  four  years  of  the  current  Consumer  Programme,  compared  to 
their  assessment  of  the  2007-2013  Programme  sees  a  slight  positive  trend45.  Equally 
positive was the perception of the benefits that most of these activities have achieved in 
the Member States.  

Outputs and results of each of the activities have been triangulated with the assessments 
of  stakeholders  made  in  the  interviews  conducted  in  all  Member  States,  Norway  and 
Iceland,  and  the  results  of  previous  specific  evaluations,  where  available.  Progress 
towards  Objective  I  during  the  evaluation  period  (the  first  four  years  of  the  current 
Consumer  Programme,  i.e.  2014-2017)  have  been  screened  through  key  indicators 
compared  with  the  baseline  situation  before  the  implementation  of  the  Programme, 
drawing  on  the  results  of  the  ex-post  evaluation  of  the  previous  Consumer  Programme 
2007-2013. 

Specific actions under Objective I 

The Rapid Alert System for dangerous non-food products (RAPEX) is a tool for national 
authorities and EU institutions to facilitate rapid information exchange and to implement 
market  surveillance.  It  also  serves  through  its  website  as  a  source  of  information  on 
unsafe products for the wider public. For the period under evaluation, more than 60% of 
interviewed  business  associations,  ECCs  and  national  authorities  expressed  their 
appreciation of RAPEX as an effective and important tool for market surveillance.  

Only  about  one  in  ten  of  the  interviewees  considered  the  system  to  be  rather  not 
effective,  mostly  consumer  organisations.46  Limitations  of  RAPEX  include  delays  in 
notification, and language issues (the system is in English only).47 

45 See Par. 3.2 Status of implementation under Objective I 
46  However,  the  majority  of  consumer  organisations  still  considered  RAPEX  to  be  at  least  moderately 
effective, see detailed interview results in the Annex to the Evaluation report. 
47 See also Ex-post evaluation of the application of the market surveillance provisions of Regulation (EC) 
No 765/2008, Final Report, May 2017, p 175-176. 

28 

 
 
 
                                                           
The  effectiveness  of  RAPEX  is  also  illustrated  by  the  measures  taken  in  response  to 
notifications  under  the  RAPEX  system  by  economic  operators  or  authorities,  such  as 
withdrawal  of  products,  sales  bans,  and  corrective  actions,  removal  of  dangerous 
products from the market or import into the EU prevention. More than 2 000 voluntary 
and compulsory measures were reported in 2016 alone. In the same year, the number of 
reactions  was  almost  double  the  number  of  notifications.  This  means  that  national 
authorities  are  systematically  following-up  notifications  that  are  circulated  in  the 
system.48 

RAPEX has been instrumental in bilateral and multilateral collaboration of the EU with 
respect to product safety. Based on RAPEX data, the Commission shares information on 
dangerous products with the OECD Global Recalls portal.49 Also, as China is the main 
country of origin for products that are subject to notification, a specific module (RAPEX 
China)  allows  for  the  swift  flagging  of  notifications  concerning  unsafe  products  from 
China. 50 

The Consumer Programme 2014-2020 defines for the first time indicators that relate to 
particular  activities,  as  well  as  associated  baselines  and  targets  to  measure  progress  for 
each of its objectives.51 For Objective  I, the targets  for the two indicators  that relate to 
RAPEX have been reached52. It can be said, therefore, that so far, the results for the first 
years of the Programme indicate a positive trend53 

Under Action 3 of the Consumer Programme, the maintenance and further development 
of  two  databases  on  cosmetics,  Cosmetic  Ingredient  Database-COSING  and  Cosmetic 
Products  Notification  Portal-CPNP  are  funded.  The  former 
the  European 
Commission’s  database  for  information  on  cosmetic  substances  and  ingredients  and 
includes all data since the adoption of the Cosmetics Directive in 1976.54  The CPNP is a 
free  of  charge  online  notification  system  created  for  the  implementation  of  Regulation 
(EC) No 1223/2009 on cosmetic products for the purposes of market surveillance, market 
analysis, evaluation and consumer information, and to Poison Centres or similar bodies 
established by EU countries (for the purposes of medical treatment).55 

is 

48  Most  of  the  reactions  in  2016  concerned  follow-up  actions  to  voluntary  measures,  indicating  that 
distributors,  manufacturers or importers in Europe follow each other by recalling the dangerous products 
notified in the system. RAPEX Annual Report 2016. 
49 https://globalrecalls.oecd.org/front/index.html#/recalls?scrollTop=129432 
50  The  absolute  number  of  notifications  involving  products  from  China  decreased  from  1262  in  2015  to 
1069 in 2016, see RAPEX Annual Reports 2015, 2016, 2017. Note, however, that the available evidence 
does  not  allow  to  draw  a  causal  link  between  RAPEX  China  and  the  decline  in  Chinese  product 
notifications.  This  could  also  reflect  e.g.  Chinese  investment  in  moving  up  the  global  value  chain,  or 
improvements in product safety for other reasons.  
51 Annex II, Regulation (EU)  No. 254/2014 of the European Parliament and the  Council of 26 February 
2014 on a multinational consumer programme for the years 2014-20. 
52 For details, see Table 1 in Chapter 3.2 Status of Implementation  
53 In addition to the indicators listed in the Regulation, additional indicators for outputs and results of the 
actions funded have been identified, see Chapter 3.3. State of Implementation  
54    Cosmetic  substances  and  ingredients  contained  in  Cosmetics  Regulation  (EC)  No  1223/2009  of  the 
European  Parliament  and  of  the  Council;  Cosmetics  Directive  76/768/EEC  (Cosmetics  Directive),  as 
amended; Inventory of Cosmetic Ingredients as amended by Decision 2006/257/EC establishing a common 
nomenclature  of  ingredients  employed  for  labelling  cosmetic  products  throughout  the  EU;  Opinions  on 
cosmetic ingredients of the Scientific Committee for Consumer Safety. 
55 See fact sheet CP 2014-20 Action 3 in the Annex of this report. 

29 

 
 
 
                                                           
The  positive  assessment  of  COSING's  effectiveness  by  stakeholders  (average  score  of 
3.8)  is  in  line  with  data  on  the  use  of  COSING,  which  confirm  that  the  database  is 
frequently accessed (almost 1 200 000 views per month, making it the by far most visited 
database  of  DG  GROW).56  For  CPNP,  as  of  December  2017  more  than  1 600 000 
products  have  been  notified  in  the  CPNP  by  42 208  organisations,  underlining  the 
practical importance of the database.  

The  Joint  cooperation  and  enforcement  actions  aim  to  promote  and  coordinate 
administrative cooperation for the application of Directive 2001/95/EC.57 These actions 
cover from assessment of risks posed by non-food consumer products and product testing 
to market surveillance operations and co-operation with customs authorities, and others. 
Specialised laboratories are selected to test products and assess risks. Such actions often 
lead to submission of notifications in RAPEX.  

In the period 2014-2016, five joint actions have been undertaken each year. For instance, 
in the 2014 joint action on acoustic toys, around 2 190 different models of acoustic toys 
were  inspected,  so  they  directly  contributed  to  consolidating  and  enhancing  product 
safety through market surveillance across EU borders, and such effectiveness is enhanced 
through the availability of RAPEX as a notification system, so that also non-participating 
countries benefit from the actions. 

All  stakeholder  groups  considered  joint  actions  to  be  effective  (average  score  of  3.9), 
with  ministries  and  national  authorities  providing  the  highest  score  (4.2).  Interviewed 
ministries  and  national  authorities  appreciated  the  coordinated  approach  to  common 
problems, the opportunity to join forces and to establish direct contacts with surveillance 
authorities  from  different  countries,  as  well  as  the  exchange  of  knowledge.  Limited 
staff/financial  resources  for  market  surveillance  and  enforcement  were  most  commonly 
indicated  as  a  factor  influencing  a  low  level  of  achievement  of  product  safety-related 
benefits. 

Networking  activities  and  events  related  to  product  safety  took  place  to  exchange 
experiences  between  Member  States  and  support  the  implementation  of  the  other 
activities,  i.e.  the  Consumer  Safety  Network,  the  CSN  permanent  subgroup  of  RAPEX 
contact, the 2016 edition of the International Product Safety Week hosted by DG Justice 
and Consumers in Brussels. 

The  interviewed  stakeholders  considered  networking  and  events  to  be  effective,  with 
ministries and national authorities being the most positive and emphasised the usefulness 
of  networking  and  events  for  the  exchange  of  best  practices  as  well  as  improving 
coordination with their counterparts in other Member States.  

The  Exchange  of  safety  enforcement  officials  include  visits,  coordination  of 
enforcement  or  investigations,  and  small  workshops.  Despite  scarce  resources  as  a 
limiting factor, the number of exchanges almost tripled from 19 in 2014 to 56 in 2017, 
which  can  be  considered  an  encouraging  number  showing  a  positive  trend.  This  is  a 
development that supports the positive assessment by national authorities.  

56 For comparison, the second most visited database is NANDO (New Approach Notified and Designated 
Organisations Information System), with an average of 500 000 views per month. 
57  Directive  2001/95/EC  of  the  European  Parliament  And  Of  The  Council  Of  3  December  2001  on 
  https://eur-lex.europa.eu/legal-
General  Product  Safety 
content/EN/TXT/PDF/?uri=CELEX:32001L0095&from=EN  

  OJ  L  11,  15.1.2002,  p.  4–17 

30 

 
 
 
                                                           
 
In  total,  officials  from  21  EU  and  EEA  states  took  part  in  exchanges.  The  top  three 
Member States  of beneficiaries have been Poland (36 officials), Bulgaria (26 officials), 
and  Croatia  (10  officials).  The  top  three  hosting  Member  States  have  been  Poland  (23 
officials), Malta (18 officials), and France (14 officials). 

The E-Enforcement Academy  is a new activity under both Objective  I (Action 2) and 
Objective  IV  aimed  at  boosting  both  the  Consumer  Protection  Cooperation  (CPC)  and 
the consumer product safety networks (CSN) abilities to conduct online investigations by 
means  of high-quality trainings and learning materials.  23 product  safety officials from 
different countries participated in webinars, and 12 officials attended master classes58.  

In spite of this limited number of participants so far, interviewees (mostly ministries and 
authorities)  gave  the  E-Enforcement  Academy  the  highest  ranking  in  terms  of 
effectiveness  in  this  Programme  area,  (average  score  of  4.2).  In  order  to  maximise  its 
potential, together with  consolidation for the initial phase, it could be assessed whether 
more  training  activities  conducted  more  frequently  and  in-person  could  attract  further 
participants to the E-enforcement Academy. 

Two  non-food  scientific  committees,  the  Scientific  Committee  on  Consumer  Safety 
(SCCS)59  and  the  Scientific  Committee  on  Health,  Environmental  and  Emerging  Risks 
(SCHEER)60 provide advice feeding into the work of EU standardisation bodies and into 
the knowledge base to further improve consumer product safety in the EU, in particular 
on cosmetic products. From April 2013 to March 2016, the SCCS and SCHEER adopted 
87 documents during a total of 306 meetings.61 An evaluation of the functioning of the 
Scientific  Committees  concluded  that  the  “opinions  of  the  Scientific  Committees  have 
generally  been  fully  responsive  to  the  information  needs  of  the  relevant  Commission 
Services,  although  with  some  variations  between  SC  [Scientific  Committees]  also 
depending on the nature of the questions addressed."62 

Objective II - Consumer information and education, developing the evidence base and 
support to consumer organisations 

58  Whereas  the  capacity  for  the  knowledge-sharing  webinars  was  set  at  30  participants  per  webinar, 
participation numbers are reported as: 21; 10; 5; 5 and 7 for webinars 1-5 respectively.58 Participation in 
the coaching webinars with a capacity of 25 participants per webinar has been 6, 4, 7 and 2 participants in 
the  four  basic  seminars  and  12  and  4  participants  in  the  two  advanced  webinars,  respectively.  These 
numbers suggest that the E-Enforcement  Academy  has  not yet fully attracted the interest of enforcement 
officials.  
59  It  provides  opinions  on  health  and  safety  risks  (chemical,  biological,  mechanical  and  other  physical 
risks) of non-food consumer products (e.g. cosmetic products and their ingredients, toys, textiles, clothing, 
personal care and household products) and services (e.g. tattooing, artificial sun tanning) 
60 The SCHEER, on request of Commission services, provides opinions on questions concerning health, 
environmental and emerging risks. In particular, the Committee provides opinions on questions concerning 
emerging or newly identified health and environmental risks and on broad, complex or  multidisciplinary 
issues  that  require  a  comprehensive  assessment  of  risks  to  consumer  safety  or  public  health  and  related 
issues not covered by other European Union risk assessment bodies 
61  During  the  term  2013-2016,  the  SCCS  adopted  60  opinions  in  the  following  areas:  Hair  dyes  (23 
opinions); Fragrances (3 opinions); Cosmetic ingredients (26 opinions); and Nanomaterial in cosmetics (8 
opinions). In addition, 3 joint opinions were adopted with SCENIHR and SCHER (Synthetic Biology I, II 
and III) as well as 6 memoranda and statements. Subsequently, in the period of April 2016 to January 2018, 
the SCCS has adopted 13 opinions in the following areas: Cosmetic ingredients (7 opinions); Hair dyes (5 
opinions); Nanomaterials (1 opinion). 
63 http://www.consumerchampion.eu/  

31 

 
 
 
 
                                                           
Key findings  

The Consumer Programme has been largely effective in developing the evidence base for 
consumer policy, as consumer scoreboards and market studies have led to policy uptake 
at EU level, and are useful for benchmarking purposes at the national level. Also, support 
to 
the  EU-level  consumer  organisation  Bureau  Européen  des  Unions  des 
Consommateurs-BEUC  is  considered  to  be  effective,  and  the  organisation  made  an 
important and consistent contribution to representing consumer interests at the EU level. 
The Consumer Champion63 training courses for consumer professionals are considered to 
be  valuable  and  highly  appreciated,  while  the  online  learning  courses  and  interactive 
platform are under-used. Capacity of consumer organisations at the national level often 
remained  insufficient  in  spite  of  these  training  measures,  mostly  due  to  a  lack  of 
resources  rather  than  to  drawbacks  of  the  activities  per  se.  Consumer  awareness 
campaigns  funded  under  the  Programme  have  achieved  mixed  results,  with  the 
campaigns'  targets  in  terms  of  hits  or  impression  achieved,  but  little  long  term  impacts 
being discernible.  

The targets set for this objective in the Regulation are already met, they relate to only one 
activity  funded  under  this  objective,  the  European  Consumer  Complaints  Registration 
System.  However,  in  spite  of  positive  indicator  values,  interviewees  emphasised  the 
efforts  needed  for  providing  complaints  data  and  suggested  that  the  system  needed 
improvement/changes.  

Key factors that influence the level of achievements related to the Programme objective 
are  often  external  in  nature:  in  the  area  of  consumer  information  and  education  they 
include limited staff and financial resources available for this purpose in Member States, 
but also the limited integration of consumer education into national curricula; in the area 
of  capacity  building  of  consumer  organisations  they  include  resource  constraints  of  the 
target organisations, which cannot appropriately be addressed by the provision of training 
alone.  

Specific actions 

The  consumer  rights  information  activities  under  Actions  5  and  6  of  the  Consumer 
Programme  2014-2064  have  included  information  campaigns  on  consumer  credit,  on 
energy  efficiency  (communication  campaign  targeting  energy  poor  households),  and  in 
2014  consumer  rights  awareness  activities  in  Croatia  (consumer  advice  services  in 
support of an EU information campaign).65 

63 http://www.consumerchampion.eu/  
64 Activities have been focused either on Member States that have joined the EU recently, or for new 
consumer rights that are subject to harmonised rules, or sectors with significant cross-border trade or high 
consumer detriment 
65  In  the  twelve  months  of  implementation  of  the  consumer  rights  awareness  campaign  in  Croatia  (Oct 
2014-Oct 2015), 23 press releases generated 351 media articles and the display campaign generated close 
to  38  million  impressions.  The  Facebook  campaign  generated  nearly  5  million  impressions,  with  16 368 
followers by its end. A subsequent Eurobarometer survey of the country’s consumers concluded that 64% 
found  the  information  they  received  about  consumer  rights  useful,  and  three  quarters  indicated  they  had 
seen  or  heard  information  messages  in  the  media  related  to  key  messages  (from  the  Evaluation  of  the 
information campaign “Raising consumers’ awareness when they take out credit”, 2016). 

32 

 
 
 
                                                           
The specific evaluation of the 2014 campaigns concluded that, while their messages were 
considered  easy  and  informative,  the  increase  in  awareness  after  the  campaign  was 
relatively  small  overall  (2%  to  5%).66  The  evaluation  of  the  second  wave  reported  that 
"stakeholders  perceived  that  the  budget  was  quite  limited  and  that  it  would,  therefore, 
have been challenging to make a lasting impact on large numbers of the target group".67. 

Although  the  stakeholders'  assessment  was  slightly  better  than  "moderately  effective" 
(3.4)  in  contributing  to  Objective  II,  some  national  consumer  organisations  argued  that 
such a contribution could be improved if they were given a larger role in these campaigns 
(campaigns have been principally carried out by specialised media agencies). The benefit 
assessment  concerning  Better  information  for  consumers  was  equally  moderate  (3.3). 
This  was  mainly  due  to  limited  staff/financial  resources  for  consumer  information,  and 
insufficient capacity of consumer organisations at national level.  

Capacity  building  and  support  to  consumer  organisations  (Action  5)  consists  of 
financial support to EU-level consumer organisations, and capacity building measures for 
national organisations.68 The financial support to BEUC was last independently evaluated 
in  2013  for  the  2007-13  contributions.69  The  findings  of  the  evaluation  confirmed  the 
organisation’s  significant  contribution  to  EU  policy-making  and  representing  consumer 
interests,  found  it  to  be  reasonably  efficient  and  well-functioning,  and  recommended 
improvements  in  its  performance  monitoring  system  (key  performance  indicators  are 
now in place). 

Interviewees,  in  particular  consumer  organisations,  considered  the  support  to  BEUC  as 
the  most  effective  activity  under  Objective  in  terms  of  information,  education  and 
networking  hub  for  national  consumer  organisations.  This  activity  received  the  highest 
average  score  for  effectiveness  of  all  activities  under  this  objective  from  interviewed 
stakeholders  (4.2),  while  its  Representation  of  consumer  interests  at  EU  level  was 
equally  rated  with  the  highest  level  of  achievement  amongst  benefits  listed  (3.6).  Not 
surprisingly, consumer organisations gave the highest average assessment rating (4.5).  

BEUC  also  manages  as  leader  of  a  consortium  the  Consumer  Champion  capacity-
building programme, which builds on the work of the previous TRACE programme,70 and 
consists of courses at the local level in the Member States as well as e-learning courses 
and  an  online  networking  platform.  Despite  statistics  growth  in  user  numbers  between 
2014  and  2017,71  BEUC  itself  noted  overall  that  the  online  platform  did  not  have  the 

66  ICF,  Evaluation  of  the  information  campaign  “Knowing  your  rights  with  regard  to  consumer  credit” 
(2014); see fact sheet CP 2014-20 Action 6 (source m) 
67 The awareness-raising campaign on energy efficiency targeting energy poor households is ongoing, so 
its outputs and results were not yet available at the time of writing 
68  Financial  support  to  EU-level  consumer  organisations  in  fact  refers  currently  only  to  the  Bureau 
Européen des Unions des Consommateurs-BEUC, which operates a multi-annual strategy under-pinned by 
a multi-annual framework programme and monitored by means of a number of key performance indicators. 
BEUC which receives a yearly core grant that constitutes just over a third of its total operational budget. In 
2016, the EU operational grant of 1.750.000 E. represented 38% of the operational BEUC budget and 32% 
of its total budget. For more details see fact sheet action 5.  
69  Evaluation  of  EU  financial  contributions  to  EU-level  consumer  organisations  (BEUC)  2007-2011, 
prepared by Van Dijk Management Consultants, 16 October 2013; see fact sheet action 5 (source n) 
70 See fact sheet for Action 5, CP2007-13 
71  –  for  example,  the  number  of  visitors  increased  from  1 247  to  40 066  and  the  number  of  registered 
organisations increased from 852 to 1 096. According to the latest available data, 542 e-learners are using 
33 

 
 
 
                                                           
success  expected,  because  of  difficulty  of  navigating  it,  language  obstacles,  overall 
culture  in  the  consumer  movement  (preference  for  face  to  face  networking)  and 
competition with other platforms (BEUC’s own internal member platform).72  

On  the  other  hand,  local  courses  were  appreciated  within  the  Consumer  Champion 
programme,  as  they  provide  space  for  networking  with  other  consumer  stakeholders  in 
the  country,  they  are  in  the  national  language  and  focus  on  country’s  specificities.73. 
However, the impact  of the Consumer Champion on the  Improved capacity of  national 
consumer organisations ranked the lowest in terms of level of achievement, particularly 
among  consumer  organisations.  The  likely  most  significant  factor  limiting  the  level  of 
achievement is the lack of resources of consumer organisations.  

In  Consumer  education  areas,  the  Consumer  Classroom  website  had  277 241  unique 
users,  25 048  registered  users  (out  of  which  6 721  were  teachers),  223  ready-to-use 
teaching resources  collected from across the EU, 544 lessons created by users, and had 
built 78 partnerships across Europe with consumer organisations, school associations and 
other interested NGOs, and also organised an annual school competition bringing student 
from  different  Member  States  together  to  compete  on  topical  consumer  issues.    Local 
courses were the most appreciated by participants (mostly from consumer organisations), 
as they provided space for networking with other consumer stakeholders in the country, 
are in the national language and focus on country’s specificities. The effectiveness of the 
Consumer Classroom also depends on the national situation that determines its uptake in 
the education system.  

Improving evidence base for policy-making (Action 4), including for designing smart 
and  targeted  regulations  and  for  detecting  any  market  malfunctioning  or  changes  in 
consumers’  needs.  It  accounts  for  the  largest  share  of  the  Programme  resources  spent 
under this objective (about 40%) also through the funding of consumer scoreboards and 
market studies.   
Based on the results of the scoreboards74, the Commission identifies markets that do not 
function well and which may require further in-depth research. Ten studies were carried 
out within the period 2014-2020, including on measuring consumer detriment in the EU, 
on pre-contractual information and billing in the energy market, on sharing economy and 
on residential prosumers in the European Energy Union.75  

the  6  online  modules,  which  are  available  in  14  languages,  on  consumer  law  (levels  I  and  II),  energy, 
financial services, telecoms and digital services. 
72  Furthermore,  the  e-learning  modules,  as  stated  by  members  of  the  European  Consumer  Consultative 
Group (ECCG) in meetings, did not respond to the needs of local professionals, were too EU-oriented and 
the  format  was  too  time-consuming  for  often-overloaded  volunteer  professionals  .BEUC,  Consumer 
Champion  evaluation  and  way  forward  –  Concept  note  (2017);  Consumer  Champion  website  report;  see 
fact sheet CP 2014-20 Action 5 (source o) and p 
73 21 courses have been organised in 9 Central European and Southern European countries, resulting in 
279 trained consumer professionals in these countries 
74  Consumer  Markets  Scoreboard:  Refinement,  Further  development  and  Analysis  of  Micro-data  (2015), 
JRC/DG Justice and Consumers; see fact sheet CP2014-20 Action 4 (source c) 
75 http://ec.europa.eu/consumers/consumer_evidence/market_studies/index_en.htm; for full details see fact 
sheet CP2014-20 Action 4 (source d). 

34 

 
 
 
                                                                                                                                                                            
Scoreboards and market studies' effectiveness is evidenced through policy uptake of their 
results at the EU and national levels76: 

  Findings of the Consumer Markets Scoreboard can help national policymakers to 

benchmark their national situation against other countries.   

  Scoreboards  have  informed  the  European  Semester  exercise  evaluations  and 
impact  assessments,  and  indicators  in  the  strategic  planning  of  DG  Justice  and 
Consumers; 

  The findings of market studies fed into policy and other Commission initiatives. 
The 2017 Study on measuring consumer detriment in the EU fed into the REFIT 
(Regulatory Fitness and Performance Programme,77  

These activities have, therefore, been effective in informing the consumer policy process. 
Alike the majority of interviewees considered both scoreboards and market studies to be 
effective  in  developing  the  evidence  base  for  consumer  policy  and  useful  also  at  the 
national level.78  Several consumer organisations complained that policymakers at the EU 
and national level did not sufficiently take the evidence base into account when making 
consumer  policy  decisions.  There  were  also  reported  shortcomings  in  some  instances 
with regard to the planning and timeliness of the evidence produced.  
The European Consumer Complaints Registration  System (ECCRS)79 - based on  a 
harmonised  methodology  for  classifying  and  reporting  consumer  complaints  and 
enquiries  -  aims  to  provide  a  broad  evidence  basis  on  consumer  issues  and  enable 
comparisons across the Member States.80  

ECCRS data has fed into the preparatory work for some initiatives and studies, often for 
triangulation purposes, including for e.g. the Study on measuring consumer detriment in 
the EU, the Evaluation of the Consumer Rights Directive and the Consumer Scoreboards 
(since 2012).81 The number of complaint bodies and countries submitting complaints data 
to the ECCRS also increased from 37 complaint bodies representing 13 countries in 2014 
to 73 complaint bodies representing 20 countries in 2015,82 thereby meeting the targets 
set in the Regulation for 2020.  

76 case study on the evidence base for EU consumer policy in Annex I summarises the evidence identified 
in this respect 
77  Activity  Report  18th  Meeting  Consumer  Markets  Expert  Group  (CMEG),  Thursday  29th  September 
2016; See fact sheet CP2014-20 Action (source i). 
78 “Better information on consumer markets and problems across the EU to benchmark the situation in my 
country with the situation in other Member States” received average assessments of 3.6 from ministries and 
national  authorities,  second  highest  in  terms  of  benefit.  See  also  the  detailed  interview  results  for  more 
details,  in  Annex  VI  of  this  report.  Authorities  use  them  e.g.  for  publications  and  as  a  basis  to  further 
monitor  their  own  markets  when  the  results  are  poor  (e.g.  Norway),  for  development  of  national  policy 
(e.g. Lithuania), or for impact assessments (Finland). 
79 in 2010, the European Commission issued a recommendation on the use of a harmonised methodology 
for classifying and reporting consumer complaints and enquiries Recommendation of 12.5.2010 
80  http://ec.europa.eu/consumers/consumer_evidence/data_consumer_complaints/index_en.htm;  see  fact 
sheet CP2014-20 Action 6 (source n) 
81 Communication with the European Commission, DG Justice and Consumers (2017) (source p) 
82  See  implementation  status  3.3  under  Objective  2.  DG  JUST  2014,  2015  Activity  Reports,  including 
Annexes; see fact sheet CP2014-20 Action 6 (sources g, h) 

35 

 
 
 
                                                           
This  contrasts,  however,  with  the  views  of  stakeholders,  who  gave  the  ECCRS  on 
average the lowest assessment for any of the activities funded under this objective.83 This 
divergence  can  be  explained  by  the  fact  that  the  targets  are  quantitative,  and  focus  on 
inputs, while stakeholder assessments instead refer to motivation, contents and usability 
of results, which have been indicated to be limited so far. Also, the ECCRS was assessed 
lowest  in  terms  of  affordability  of  the  costs  borne  by  each  organisation  relative  to  the 
benefits it received. It can therefore be concluded that in spite of the achievement of the 
related targets, the ECCRS needs further review.  

Objective III Consumer rights and redress 

Key findings  

The  funded  activities  such  as  the  ODR  platform,  awareness  campaigns  on  ADR/ODR 
and related networking and events complement each other and have been an appropriate 
choice to reach the objective. Also, behavioural and other policy studies have contributed 
to creating a fundament for evidence-based consumer policy and legislation.  

The ODR platform has been relatively successful in attracting consumers to register their 
complaints. The target for 2020 in terms of complaint numbers is likely to be achieved. 
However,  the  platform  has  been  less  effective  in  reaching  its  aim  to  improve  access  to 
ADR,  with  so  far  2%  of  the  registered  complaints  reaching  an  ADR  body.  Possible 
reasons  include  the  early  stage  of  implementation  of  the  ODR  platform,  a  limited 
awareness of consumers and traders of the platform, and the reluctance of traders to settle 
their disputes via ADR.  

The main benefit of the ODR platform appears to be that traders contacted through the 
platform often informally solve the problem directly with the affected consumers without 
any involvement of an ADR scheme. Positive trends with respect to accessibility of and 
consumer  satisfaction  with  ADR  can  be  observed  based  on  EU  survey  data.  They 
possibly  reflect  ongoing  efforts  in  Member  States  to  improve  ADR  systems  and  a 
broader recognition of ADR as an efficient means of redress. 

Behavioural  studies  are  an  essential  tool  to  support  evidence  based  policymaking  that 
in  real  markets  with  real  companies, 
considers  how  real  consumers 
complementing evidence from legal and economic studies. However, as for Objective II, 
stakeholders think that policymakers do not make sufficient use of these studies, or that 
the studies could be better promoted. Several studies have however fed directly into the 
development  of  EU  consumer  policy  initiatives,  with  the  practical  value  of  the  studies 
being confirmed by stakeholders. 

interact 

Specific actions 

The  actions  funded  under  this  objective  are  targeted  to  address  the  problems  -  as 
summarised  in  the  baseline  and  in  the  2011  impact  assessment  of  the  Consumer 

83 Most interviewees who commented on the ECCRS suggested that it needed considerable improvement. 
It was mentioned by a number of interviewees, for example, that the classification used is too complicated 
or not practical at the national level. It was reported that the management and maintenance of the database 
is  resource  intensive  on  the  Commission  as  well  and  that  due  to  recent  capacity  constraints,  the  data 
provided  by  Member  States  can  temporarily  not  be  further  processed  by  the  Commission  for  use  in  the 
database. 

36 

 
 
 
 
                                                           
Programme  2014-2020  -  concerning  Sub-optimal  protection  of  consumer  rights,  
Regulatory  fragmentation  of  consumer  legislation,  Problems  faced  by  consumers  when 
trying  to  secure  redress,  and  need  to  further  improve  the  integration  of  consumer 
interests in EU policies:8485.  

Facilitating  access  to  alternative  dispute  resolution  mechanisms  for  consumers  through 
an  European  Online  Dispute  Resolution-ODR  platform,  as  well  as  related  awareness 
campaigns  and  networking  activities  under  Action  9  account  for  roughly  half  of  the 
Programme resources spent under this objective. 86  

From  15  February  2016  to  15  February  2017,  1.9  million  people  visited  the  ODR 
platform87.  On  average  the  website  received  over  160 000  visitors  per  month  and  the 
number  of  complaints  registered  on  the  ODR  platform  is  already  slightly  more  than 
halfway to its 2020 target after the first 22 months of the ODR platform’s existence. 

The Commission’s 2017 report on the functioning of the ODR platform indicates that in 
85%  of  the  cases,  complaints  were  automatically  closed  within  30  calendar  days  after 
submission,  meaning  that  the  consumer  and  the  trader  failed  to  agree  on  a  competent 
ADR  body.  88  Only  less  than  1%  of  the  complaints  that  were  lodged  through  the  ODR 
platform reached a final outcome through an ADR procedure. However, the survey report 
shows that around 44% cases (including automatically closed cases) are settled directly 
by the parties following the contact via ODR platform89.  

It  can  be  stated,  therefore,  that  the  ODR  platform  has  been  successful  in  attracting 
consumers to register their complaints; however, its impact on improving access to ADR 
is  difficult  to  assess  and  quantify.  Further  close  monitoring  and  a  more  in-depth 
assessment  in  some  years  will  be  needed  to  improve  access  to  ADR.90  Traders’ 
willingness  to  engage  in  it  may  depend  on  a  number  of  factors,  such  as  a  very  slow 
judicial system or high litigation costs that act as an incentive for traders to not to engage 
in ADR, since they do not have much to fear as consumers will not normally go to court. 
Another factor is the costs of ADR proceedings91. 

84 COM(2011) 1320  final, Impact Assessment accompanying the document Proposal for a Regulation of 
The European Parliament and of the Council on a consumer programme 2014-2020, p 13-15. 
85  These  problems  were  also  emphasised  in  the  mid-term  evaluation  of  the  previous  Programme,  which 
concluded  that  the  2004-2007  and  2007-2013  Programmes  had  been  increasingly  successful  in  the 
integration of consumer policy into relevant EU policies, and suggested pursuing efforts in this field, while 
addressing  emerging  challenges  such  as  digitalisation.  The  report  also  referred  to  the  need  to  make 
progress regarding access to redress, and consumer awareness about the means of redress 
86  Report  from  the  Commission  to  the  European  Parliament  and  the  Council  on  the  functioning  of  the 
European Online Dispute Resolution platform established under Regulation (EU) No 524/2013 on online 
dispute resolution for consumer disputes, COM(2017) 744 final (henceforth: ‘ODR report’) 
87  Action  9  under  Objective  III  of  the  Consumer  Programme  2014-2020  concerns  facilitating  access  to 
dispute  resolution  mechanisms  for  consumers,  in  particular  to  alternative  dispute  resolution  schemes, 
including through a Union-wide online system and the networking of national alternative dispute resolution 
entities 
88 As of February 2017, about 2500 complaints were registered on the platform on a monthly basis.88 The 
most complained-about sectors were consumer clothing and footwear (11.5%), airline tickets (8.5%), and 
information and communication technology goods (8%).  
89 European Commission, ODR report (2017) 
90 See table in par. 3.2 Implementation status under Objective III 
91 In Germany, for example, in some ADR schemes the trader has to bear costs even if it wins the case 
entirely,  which  may  act  as  a  disincentive  to  participate  in  the  first  place.  It  is  also  possible  that  traders 
37 

 
 
 
                                                           
Awareness of the ODR platform, and of ADR, is a prerequisite of their use. Therefore, 
communication activities on ADR/ODR have included awareness-raising campaigns on 
social media, high-level events with traders, and enforcement activities (web-scraping) to 
determine  the  level  of  traders’  compliance  with  the  ODR  Regulation.92  In  addition,  in 
2017  the  Commission  contracted  a  web-scraping  study  of  EU  Traders’  website  to 
examine  the  current  state  of  compliance  of  online  traders  in  the  EU  with  the  ODR 
Regulation.  More  than  20 000  web  shops  across  the  EU  were  examined  and  findings 
showed that traders’ compliance with their obligation to include the ODR link depends 
on the size, country and sector of a trader.’  

The  increasing  confidence  in  cross-border  e-commerce  and  satisfaction  with  ADR, 
therefore,  is  a  beneficial  environment  for  the  activities  funded  under  the  Consumer 
Programme,  especially  the  ODR  platform,  in  which  increasing  consumer  demand  for 
such a tool can be expected93  

Within  the  framework  of  the  Consumer  Programme  2014-2020,  the  Commission 
financed  six  behavioural  studies  between  2014  and  201794:  stakeholders  in  general 
appreciated  the  approach  of  basing  consumer  policy  and  legislation  on  evidence,  and 
considered  behavioural  studies  as  effective  and  potentially  helpful  for  policymaking. 
However,  remarks  were  raised  on  the  actual  limited  use  of  these  studies  by  policy-
makers.  
A case study on the evidence base95 identified however a number of examples where it is 
expected that the results of the studies contribute to a better understanding of consumers' 
behaviour  in  the  market,  support  the  enforcement  of  consumer  protection  rules  in  the 
online  environment,  and  inform  policy  options  to  enhance  consumer  protection  in  the 
online environment or contribute to activities by different Commission services (e.g. DG 
ENV, GROW, ENER, JRC). 

Among the other studies, three have informed the development of EU consumer policy 
initiatives, namely the study which contributed to the recast of the CPC Regulation96, the 
consumer market study on guarantees, which fed into the proposals on digital contracts 
and informed the REFIT of the Consumer Sales and Guarantees Directive 1999/44/EC97 
and  the  study  on  transparency  of  online  platform  into  the  New  Deal  for  consumers98. 

consider  ADR as a last resort option, and prefer their own complaint handling  mechanisms.  An ongoing 
campaign  by  the  European  Commission  addressed  to  traders  is  expected  to  provide  further  insights  on 
traders’ attitudes towards ADR and their motivations 
92By  the  end  of  2016,  awareness-raising  campaigns  on  ADR/ODR  had  a  Facebook  reach  of  21  million 
users and a Twitter reach of 9 million users compared to an overall target of 10 million people. The two 
waves  of  the  ODR  video  campaign  achieved  a  total  of  12.8  million  views  (compared  to  a  campaign 
forecast  of  3  million  views)  and  285 623  website  clicks  (compared  to  a  campaign  forecast  of  132 000 
views).  
93 See par 3.3 Status of Implementation under Objective III 
94  Study  on  consumers’  decision-making  in  insurance  services;  Behavioural  study  on  food  choices  and 
eating habits; Behavioural study on advertising market practices in online social media; Behavioural study 
on  the  transparency  of  online  platforms;  Behavioural  study  on  consumers  engagement  in  the  circular 
economy; and Behavioural study on digitalisation of financial services.  
95 See Annex I (PAGE 269) to the evaluation report. 
96 Regulation (EC) No 2006/2004 
97 See the activity report of the 17th Meeting Consumer Markets Expert Group (CMEG), Wednesday 17th 
February 2016. 
98 COM/2018/0184 final and COM/2018/0185 final and - 2018/090 (COD) 

38 

 
 
 
                                                                                                                                                                            
 
Other studies are ongoing,  in order to support smart regulatory action, such as ex-ante 
and ex-post evaluations, impact assessments, public consultations, and the evaluation and 
simplification of existing legislation.99  

Among  other  activities,  the  Citizens’  Energy  Forum  was  considered  to  be  largely 
effective (average rating 3.8) as a “space for concertation and exchange of policy views” 
100.  The  recommendations  that  came  out  of  the  Forum  were  widely  used  by  the 
Commission  when  proposing  the  ‘Clean  Energy  Package  for  all  Europeans’.    Also  two 
working  groups  on  consumer  policy  have  been  convened  within  the  framework  of  the 
Citizens’  Energy  Forum,  including  the  Vulnerable  Consumer  Working  Group.101 
Stakeholders considered that the Citizens’ Energy Forum made a notable contribution to 
consumer  policy  and  legislation  at  the  EU  level,  in  particular  noting  that  the 
recommendations  that  came  out  of  the  Forum  were  widely  used  by  the  Commission 
when proposing the ‘Clean Energy Package for all Europeans’.102  

Other networking  activities and events  include  meetings of the  Financial  Services User 
Group  (FSUG)103  providing  advice  to  the  Commission  in  the  preparation  and 
implementation  of  legislation  or  policy  initiatives  affecting  the  users  of  financial 
services.104.  The  Multi-Stakeholder  Groups  (MSGs)  on  Environmental  Claims  and  on 
Comparison Tools set up as the result of the Consumer Summit brought together industry 
representatives, NGOs and national authorities with the aim to improve compliance with 
the Unfair Commercial Practices Directive 2005/29/EC (UCPD) in these two areas. The 
MSG  on  Comparison  Tools'  Key  Principles  for  Comparison  Tools  have  fed  into  the 
UCPD  Guidance  and  have  also  been  referenced  in  the  Communication  on  Online 
Platforms and the Digital Single Market published on 25 May 2016.  

Interviewees unanimously found these networking activities and events very useful, and 
attributed a multiplier effect to them in that information gained through these activities is 
passed on to the relevant services at the national level. The results of the evaluation also 
confirm  that  considerable  outputs  and  results  were  produced,  which  fed  into  the  policy 
process.   

99 See Objective III, Action 8 in Annex I of the Regulation (EU) No. 254/2014 of the European Parliament 
and the Council of 26 February 2014 on a multinational consumer programme for the years 2014-20. 
100  The  Citizens'  Energy  Forum  was  established  in  2007.  It  meets  on  an  annual  basis  in  London  and  is 
organised with the support of Ofgem, the UK regulatory authority for electricity and gas. 
101  Established  in  2012,  it  feeds  the  discussions  in  the  Citizens’  Energy  Forum  and  support  the 
implementation  of  EU  energy  legislation  relating  to  vulnerable  customers.  The  working  group  met 
regularly  and  released  a  Guidance  Document  on  Vulnerable  Consumers  in  November  2013  as  well  as  a 
Working  Paper  on  Energy  Poverty.  Conclusions  of  the  8th  meeting  of  the  Citizens’  Energy  Forum, 
London, 
Forum  website: 
also 
https://ec.europa.eu/energy/en/events/citizens-energy-forum-london .  
102  In  the  first  three  years  of  the  Programme,  the  FSUG  held  25  meetings,  issued  35  opinions  and  12 
additional  studies  or  papers  on  issues  affecting  the  users  of  financial  services.See  the  detailed  interview 
results in Annex VI of this report for further details. 
103 See Decision 2010/C 199/02. This decision was recast in 2017 by Decision C(2017) 359. 
104 From 2014 to 2016, the FSUG issued 35 opinions as well as 12 additional studies or papers on issues 
affecting the users of financial services 

the  Citizens’ 

February 

Energy 

23-24 

2016; 

see 

39 

 
 
 
 
 
                                                           
Objective IV: Enforcement  

Key findings 

The  Consumer  Programme  2014-2020  is  on  track  to  achieve  Objective  IV,  as  is 
evidenced  by  significant  progress  made  in  reaching  most  of  the  targets  set  in  the 
Programme.  The  activities  funded  complement  each  other  well  and  have  been  largely 
effective  in  supporting  enforcement  of  consumer  rights  by  strengthening  cooperation 
between national enforcement bodies and by supporting consumers with advice. 

Activities related to the Consumer Protection Cooperation Network-CPC have grown in 
importance and seen improvement in terms of effectiveness. A new knowledge exchange 
platform (IT tool) has also been added to support collaborative work and to share results 
with  the  wider  CPC  Network.  However,  there  are  still  differences  between  Member 
States in making use of the CPC System and to engage in enforcement  requests, with a 
significant drawback in achieving Objective IV being the often long response times in the 
network. 

Exchanges  of  enforcement  officials  are  an  appreciated  activity  that  has  seen  increased 
participation,  but  that  is  unevenly  used  by  Member  States.  Also,  the  E-Enforcement 
Academy  has  received  a  high  assessment  of  effectiveness,  although  participation  in  its 
first  year  in  operation  has  remained  lower  than  planned,  especially  in  web-based 
modules. 

The  European  Consumer  Centres-ECCs  have  established  themselves  further  during  the 
current  Programme  as  an  important  institutional  component  of  EU  consumer  law 
enforcement  policy.  The  output  of  the  ECC-Net  is  significant,  and  the  quality  and 
timeliness  of  the  ECCs’  services  is  also  assessed  positively  in  the  recent  specific 
evaluation, despite disparities in this respect between ECCs in different Member States. 
The main challenge for the ECCs is still their visibility.   

EU  survey  data  shows  that  in  parallel  to  the  implementation  of  activities  under  the 
Consumer Programme, trust of consumers that public authorities protect their rights, and 
that retailers generally respect consumer rights has increased. This correlates with a slight 
reduction of problems experienced by consumers. Two thirds of retailers consider public 
authorities to actively monitor and ensure compliance with consumer legislation in their 
sector. However, this percentage has decreased over the last years. 

With some resemblance to the situation discussed regarding product safety, limited staff 
and  financial  resources  of  consumer  protection  authorities  in  the  Member  States  are 
considered  key  factors  influencing  the  level  of  achievements  related  to  the  Programme 
objective; other key factors include the rapid innovation of products and services, as well 
as  new  distribution  channels  that  make  effective  consumer  protection  more  difficult. 
While this development offers many advantages for consumers as well as for businesses, 
there  are  also  increased  risks  for  widespread  infringements  of  consumer  rights  and 
difficulties  with  enforcement  of  consumer  rights.  The  Digital  Single  Market  Strategy 
therefore  highlighted  the  "need  for  more  rapid,  agile  and  consistent  enforcement  of 
consumer  rules  for  online  and  digital  purchases  to  make  them  fully  effective".105  More 

105 See Impact Assessment, p. 6 with reference to Commission Communication "A Digital Single Market 
Strategy for Europe" COM (2015) 192 final; see also Upgrading the Single Market: more opportunities for 
people and business, COM/2015/0550 final. 

40 

 
 
 
                                                           
recently,  effective enforcement of consumer rights was made  a central  part of the New 
Deal for Consumers launched by the European Commission. 

The 2011 mid-term evaluation of the 2007-2013 Programme and the impact assessment 
for the current Programme from the same year had concluded that problems continued to 
exist in the area of enforcement of consumer rights, particularly in a cross-border context 
and  suggested  to  further  increasing  the  coordination  within  the  CPC  Network  and 
enforcement authorities. The role of effective and efficient enforcement of EU consumer 
law has become particularly prominent with the advance of digitalisation and the Internet 
and the rapid growth of online business-to-consumer trade.  

Specific actions 

While the responsibility  for enforcement of EU consumer law and policy lies primarily 
with  the  EU  Member  States,  the  2004  CPC  Regulation106  established  the  Consumer 
Protection Cooperation Network (CPC) of public enforcement authorities responsible 
for  consumer  law  enforcement  in  the  Member  States  (so  called  national  competent 
authorities, or NCAs) in cases of cross-border consumer law infringements.  
Under  the  CPC107  system  (CPCS),  the  main  platform  through  which  exchanges  of 
information  and  enforcement  requests  between  competent  authorities  are  taking  place, 
the database initially suffered from a technical problems as well as a lack of experience 
and  understanding  on  the  part  of  authorised  users.108  Then,  it  has  improved,109  and  a 
recently introduced CPC knowledge exchange platform complementing the database was 
considered to be an effective innovation.110 

Several  interviewees  in  the  current  Programme  evaluation  emphasised  the  role  of  the 
CPC  Network  for  developing  a  common  understanding  of  the  CPC  Regulation  and  a 
more harmonised approach to implementation.111 Overall, the CPC Networks is therefore 
considered by stakeholders to be largely effective. 

The  CPC  Regulation  also  includes  a  provision  on  coordinated  market  surveillance  and 
enforcement activities in cases of intra-Community infringements that harm the interests 
of  consumers  in  more  than  two  Member  States  (Article  9).  EU-wide  screenings  of 
websites, commonly known as sweeps are carried out. So far, four sweeps were funded 
under the Consumer Programme 2014-2020.112  

106 When in this section the term CPC Regulation is used, the Regulation (EC) No 2006/2004 is envisaged 
and not the new Regulation EU/2017/2394.   
107  Report  from  the  Commission  to  the  European  Parliament  and  to  the  Council  on  the  application  of 
Regulation (EC) No 2006/2004, Brussels, 2.7.2009 COM(2009) 336 final  (hereinafter: First Commission 
Report), p. 4. 
108 See Part 2 of the evaluation of the Consumer programme, which provides an ex-post evaluation of the 
activities under the Consumer Programme 2007-2013 
109  For  instance,  including  machine  translation  of  documents  in  the  functionalities  of  the  system  was 
considered to be an upgrade that could facilitate the communication between NCAs, if technically feasible. 
110  Under  the  new  CPC  Regulation  2017/2394  repealing  Regulation  (EC)  No  2006/2004  (New  CPC 
Regulation)  that    entered  into  force  on  17  January  2018  and  shall  apply  from  17  January  2020  -  the 
Commission  will  have  to  set  up  and  maintain  a  database  that  is  able  to  provide  safe  environment  for 
exchanges for new processes provided for in the new CPC Regulation. 
111 A view  which  was confirmed during the already  mentioned meeting of the  CPC Committee  with the 
evaluation team on 22 February 2018 by several participants. 
112 See fact sheet for CP2014-20 Action 10. No number of screened websites was available for 2017. 

41 

 
 
 
                                                           
The  effects  of  sweeps  assessed  through  a  follow-up  screening  showed  that  the  level  of 
compliance  among  traders  with  EU  consumer  law  has  increased  considerably,113 
indicating  the  effectiveness  of  the  sweeps.  Sweeps  enable  authorities  to  obtain 
information on the processes and problems in other Member States and to take actions ex 
officio.  

The  so-called  Joint  Actions  require  the  concerned  traders  to  cease  unfair  commercial 
practices  in  areas  of  common  interest  across  the  EU.  The  CPC  Network  has  so  far 
concluded 
the  current  Consumer 
Programme.114  Joint  actions  have  been  assessed  as  effective  and  were  considered  to 
represent a “further step in enforcement cooperation” in earlier, specific evaluations.115  

three  coordinated  enforcement  actions  under 

The added value of common enforcement actions has been evidenced and underlined also 
in  the  studies  that  prepared  the  review  of  the  CPC  Regulation.116  This  joint  approach 
enhances legal certainty and the chances of achieving compliance and offers a more cost-
effective solution  and received positive assessment  by stakeholders. Both limitations in 
the legal framework provided by the CPC Regulation117 as well as practical difficulties, 
have  however  influenced  the  achievement  of  the  Programme  objectives.  Problems  of 
coordination of joint actions were reported for the leading Member States in ensuring the 
participation of other Member States together with costs of accounting and reporting118  

The  functioning  of  the  CPC-Network  is  supported  through  training  activities,  which 
include the exchange of CPC enforcement officials and the E-Enforcement Academy. 
The exchanges of officials have taken off slowly, but are gradually expanding. Compared 
to  the  first  years  after  the  entry  into  force  of  the  CPC  Regulation,  the  total  number  of 
exchanges  has  seen  a  threefold  increase  -  from  62  CPC  exchanges  for  the  years  2009-
2013 to 196 CPC exchanges for the years of 2014-2017 – though it remains still limited 
with an uneven Member States’ engagement119.  

113 For the 2014 sweep, 46% of checked websites were found to be in compliance with EU consumer law 
before  the  sweep,  and  82%  in  compliance  after  the  sweep.  For  the  2015  sweep  the  numbers  are  37% 
websites in compliance before the sweep and 88% after. No comparable data is yet available for the 2016 
and  2017  sweeps.  See  fact  sheet  for  CP2014-20  Action  10;  Fourth  Commission  Report,  p.  12;  Impact 
Assessment, p 42.  
114 On in-app  purchases in online games  in 2014, on car rentals in 2015 and on contract terms of  social 
media service providers in 2016. 
115 See Fourth Report, p. 5. 
116 See Third Report, p. 5; Impact Assessment. With the rapid growth of online trade and the emergence of 
large  business  actors  acting  on  a  global  scale,  the  same  infringement  often  affects  consumers  in  several 
Member  States.  Therefore,  a joint  action  by  some,  or  all, of  the  CPC  authorities  in  cooperation  with  the 
Commission has the advantage of greater authority and leverage and avoiding parallel actions. 
117 In terms of legal impediments, it has been pointed out that the role of the Commission in these actions 
was not clarified in the CPC Regulation. The rights and obligations of participating Member States were 
likewise not set out in detail. Therefore, the new CPC Regulation 2394/2017 outlines with greater care the 
procedural steps and the role of different actors in the action and strengthens the role of the Commission 
(see in particular Chapter IV). 
118 Impact Assessment, p. 103-104, External Evaluation, p. 103.  
119 A few Member States, such as Estonia, Sweden, the Netherlands and Belgium have been particularly 
active in sending officials, i.e. using the exchange scheme as beneficiaries. In a similar manner, there are 
some countries that figure prominently in the statistics as hosts of enforcement official exchanges, such as 
the  UK,  Sweden,  the  Netherlands  and  Spain.  There  are  also  countries  that  make  little  or  no  use  of  the 
scheme.  

42 

 
 
 
                                                           
Such  exchanges  are  considered  important  and  useful  for  enhancing  knowledge  and 
understanding  about  the  system  of  consumer  protection  and  enforcement  practices  in 
other  Member  States.  Among  the  factors  reducing  the  interest  in  exchanges  and  their 
usefulness, language barriers, lack of time and resources on the part of both sending and 
receiving authorities are included.120  

The  E-Enforcement  Academy  (see  also  references  under  objective  I)  seeking  to  build 
capacity and improve enforcement with particular focus on online infringements caters to 
the needs of both the CPC Network and the Consumer Product Safety Network.121 Total 
participation in on-site and virtual events (webinars) in 2017- starting year - amounted to 
155  persons,  below  the  actual  capacity  of  the  training  activities.122.Although  the 
E-Enforcement  Academy  has  not  yet  fully  attracted  the  interest  of  enforcement 
officials.123  

The  second  main  action  funded  under  the  Consumer  Programme  is  the  network  of 
European Consumer Centres (ECCs) set in each of the 28 EU Member States, as well 
as  in  Norway  and  Iceland.  The  ECCs  support  consumers  in  exercising  their  rights  in 
relation to cross-border issues by giving free advice and practical assistance. Each ECC 
is co-funded by the Commission and the Member State where the centre is based.  

Despite these common requirements, the ECCs differ considerably in size, capacity and 
institutional  characteristics.  These  differences  are  at  least  partly  related  to  the  different 
institutional organization of consumer protection in the respective countries.124  

The 2017 specific evaluation of the ECC-Net systematises information on average times 
for  answering  information  requests  and  for  handling  complaints  by  individual  ECCs 
across  the  Member  States.  The  performance  of  ECCs  is  further  analysed  through 
consumer satisfaction surveys and mystery shopping tests. The overall evaluation in the 
Draft Status Report is positive, in line with the view of the stakeholders interviewed for 
this Programme evaluation. The Status Report provides detailed assessments of the ECC 
performance regarding:  

 

Information  provision,  in  2016  the  ECCs  handled  44  000  information  requests, 
which took them on average approximately five days each.125  

  For the handling of complaints, the ECCs managed to improve the time it takes to 
deal with complaints, despite a substantial increase in the number of complaints 
handled  (the  volume  almost  doubled  since  2007).126  In  terms  of  the  outcome  of 
complaints, in 2015, 51% of the shared cases (cases handled with the involvement 
of traders) were resolved amicably. For around one third of the disputes in 2015 

120 See the results of the interviews, Annex VI. 
121 Impact Assessment, p. 11. 
122 The  number of participants from the  CPC Network  has been consistently  higher than  the respective 
number for the CSN Network, Participation in the master classes has been higher than in the webinars.  
The  highest  turn  out  is  reported  for  the  two  CPC  enforcement  workshops  in  Brussels  with  20  and  13 
participants respectively, with a capacity of 30 participants per workshop 
123 Among these countries are Bulgaria, Croatia, Czech Republic, Greece, Germany, Italy and Romania. 
124 in some Member States the ECC is hosted by the public authority responsible for consumer protection, 
whereas in others they are affiliated to consumer associations or a foundation 
125 See Draft Status Report, p. 45. 
126 In 2016 it took on average 79 days to handle a normal complaint (down from 114 in 2015). 

43 

 
 
 
                                                           
and  2016,  no  solution  could  be  found.  Around  16%  of  these  cases  were 
transferred to ADR bodies.127  

  Enhancing ECCS' visibility is on the whole positively assessed. However, in spite 
of meeting and surpassing the targets set in the Consumer Programme and despite 
the  promotional  efforts  on  the  part  of  the  ECCs,  their  overall  visibility  is  still 
considered rather low. 

The Status Report emphasises the existence of significant differences in the level 
of services provided by ECCs across Member States. These differences are visible 
in all aspects of the activities of the Centres.128 

The  three  types  of  exchanges  known  as  information  requests,  alerts  and  enforcement 
requests,  respectively129  as  well  as  time  limits  for  handling  of  information  and 
enforcement requests have been used in the Regulation on the Consumer Programme as 
indicators for measuring the level of information flow within the CPC Network.130 

In  a  summarised  way,  it  can  be  said  that  two  of  the  indicators  measuring  the  level  of 
information  flow  within  the  CPC  Network  (i.e.  related  to  information  requests, 
enforcement requests) show a substantial increase from the 2011-2013 baseline period to 
the year 2017, whereas the third one (alerts) remains stable.131 

As for the timely handling of information and enforcement requests, the targets set in the 
Programme  for  information  requests  is  on  track  to  be  reached.  The  targets  set  by  the 
Consumer Programme for the ECC-Net have already been more than met 

To what extent do the activities and outputs of the actions match the objectives of the 
programmes?  

The  intervention  logic  of  the  Consumer  Programme  2014-2020  and  the  answers  to  the 
effectiveness  questions  have  indicated  that  the  activities  and  outputs  related  to  the 
activities under the Consumer Programme on the whole match the stated objectives for 
each Programme area. No activities or outputs have been identified that would not match 

127 See Status Report, p. 56-57. 
128  For  instance,  the  gap  between  countries  with  respect  to  the  number  of  complaints  and  number  of 
information requests is very significant in the case of some ECCs, also when considered in proportion to 
population  size.  The  Status  Report  also  notes  significant  cross-country  differences  in  the  timeliness  and 
quality of service 
129 There are three types of exchanges between participating authorities: information upon request (Article 
6), information without request (Article 7) and request for enforcement action (Article 8). 
130  To  measure  achievements  of  Objective  IV,  the  regulation  defines  five  indicators,  of  which  the  first 
consists  of  three  sub-indicators  (bringing  the  total  number  to  seven.  See  table.in  par.  3.3.  Status  of 
Implementation under Objective IV 
131 In the CPC Network, significant fluctuations in the types and numbers of of request in different years 
can  be  observed,  which  likely  depend  on  external  circumstances,  and  the  preferences  of  enforcement 
authorities for particular types of requests. When considering the overall information flow on basis of the 
annualised averages, the total number of requests per year has overall increased by 16% (from the baseline 
value of 277 requests per year for the period 2011-2013 to a total of 320 requests per year during the 2014-
2017 period), which confirms an increasing information  flow through the  network and the trend towards 
achieving the related targets. 

44 

 
 
 
 
                                                           
one of the four specific objectives and the set of specific actions set out in Annex I of the 
implementing Regulation (EU) No 254/2014 related to these objectives.  

5.2 EFFICIENCY 

5.2.1. Which were the costs and the benefits of the actions? 

Of  the  EUR  188.8  million  earmarked  for    the  seven-year  period  from  2014  to  2020,  a 
total of EUR 95.4 million (50,53%) had been committed as of the end of 2017.  

 The  types  of  costs  involved  in  the  actions  undertaken  under  the  programme  consist 
mainly of: 

- Operational costs of actions under the four objectives;   

-  costs  of  actions  that  cover  multiple  objectives,  such  as  travel  and  subsistence  for 
monitoring  execution  of  actions,  events,  meetings,  support  staff  for  IT  system 
maintenance, etc.   

The  quantification  of  Programme  costs  in  the  external  evaluation  focuses  on  direct 
Programme costs and co-financing contributions of beneficiaries, for which unambiguous 
data is available. Other costs are not considered. 

Regarding  benefits  of  the  programme,  the  external  programme  evaluation  has  provided 
limited  quantified  data  and  mostly  refers  to  a  more  rich    qualitative  assessment  of  the 
benefits of the programme by stakeholders.  

Benefits can be categorized as follows:  

- Benefits for direct beneficiaries (national authorities, consumer associations) 

- Direct and indirect benefits for EU consumers  

- Direct and indirect benefits for businesses operating in the single market  

- Direct and indirect benefits for national authorities  

- General social and economic benefits  

5.2.2. Justification of cost distribution and prioritisation  

The distribution of funding 2014 - 2017 between objectives was:  

Objective I: EUR 13.1 million 

Objective II: EUR 35.1 million  

Objective III: EUR13.0 million  

Objective IV EUR 30.2 million  

Approximately 4% of the budget was used to fund cross-cutting activities, such as travel 
costs for events, meetings, support staff for IT system maintenance, etc.  

45 

 
 
 
 
 
5.2.3. Proportionality of cost vs benefits  

The  external  evaluation  did  not  provide  sufficient  information  to  calculate  the 
proportionality of costs vs benefits.  

5.2.4. Factors influencing efficiency  

The  external  evaluation  found  that  stakeholders  and  beneficiaries  consider  that  the 
actions/activities  are  clearly  defined,  that  the  annual  work  programmes  are  transparent 
and  the  Programme  is  well  structured.  The  evaluators  did  not  identify  any  major  gaps, 
inconsistencies or overlaps between the activities funded.  

Potential  for  efficiency  gains  identified  in  the  mid-term  evaluation  of  the  Consumer 
Programme  2007-2013  in  the  Programme  implementation  were  addressed  through 
simplification of procedures for the financing of the exchange of officials and ECC net.  

For 
its 
the  Consumer  Programme,  EUR  188.8  million  were  earmarked  for 
implementation  over  the  seven-year  period  from  2014  to  2020,  of  which  a  total  of 
EUR 95.4 million (50, 53%) had been committed as of the end of 2017. The following 
figure  presents  the  breakdown  of  funds  committed  under  the  Consumer  Programme 
between 2014 and 2017 per objective. 

5.2.5 Efficiency per objective 

Figure 5: Proportion of funds committed under the Consumer Programme 
2014-2020 by objective, 2014-2017  

Source: Civic Consulting, based on 2014-2017 budget data provided by DG Justice and Consumers.  

As  shown  in  the  figure,  the  two  objectives  that  received  the  highest  share  of  funding 
between 2014 and 2017 were Objective II: Consumer information, education and support 
for  consumer  organisations  (EUR 35.1 million)  and  Objective  IV:  Enforcement 

46 

4%14%37%14%31%Objective IV: EnforcementObjective II: Consumer Information & EducationObjective I: SafetyObjective III: Rights & Redress 
 
 
 
 
 
 
(EUR 30.2 million). Activities funded under Objective I: Safety and Objective III: Rights 
and  redress  consumed  EUR 13.1  million  and  EUR 13.0  million,  respectively. 
Approximately  4%  of  the  budget  belongs  to  the  ‘Administrative’  budget  line,  which  is 
used  to  fund  cross-cutting  activities,  such  as  travel  costs  for  events,  meetings,  support 
staff for IT system maintenance, etc.  

EUR 13.1  million,  or  14%  of  the  funds  committed  under  the  Consumer  Programme 
between 2014 and 2017, were spent on activities related to Objective I.  The following 
figure shows a detailed breakdown of the funds committed under this objective between 
2014-2017 by main activity. 

Figure 6: Breakdown of funds committed under Objective I by type of 
activity, 2014-2017 

In the four  years under  consideration, the  amount  committed for RAPEX totalled EUR 
2.9 million, or 3.0% of total Programme costs. Given that the number of notifications in 
the RAPEX system was 8 658 in this period, the average Programme cost per notification 
was EUR 335 (equivalent to EUR 10.8 per notification and participating country), which 
appears very proportionate. 

According  to  stakeholders,  the  Consumer  Programme  achieved  the  benefit  of  better 
information on unsafe non-food products for enforcement authorities with a high average 
rating of 4.0 (on a scale of 1 to 5). This was the highest assessed benefit discussed with 
stakeholders regarding product safety.  

During  the  evaluation  period,  the  amount  committed  for  joint  cooperation  and 
enforcement  actions  in  the  area  of  non-food  consumer  product  safety  was  EUR 6.2 
million, equalling 6.5% of total Programme costs. This amount covers 70% of the budget 
for such actions as co-financing requirements apply.  

Five  joint  actions  on  product  safety  have  been  undertaken  each  year  that  led  to 
enforcement actions on many of the products tested. Stakeholders noted that joint actions 
provided participants with good knowledge of new products and new market surveillance 
methods  and  enabled  them  to  share  experiences  on  best  practices  and  apply  similar 
approaches in the Member States as well as save resources and test products which they 
would otherwise not have been able to test.  

47 

14%RAPEX  (22%)Joint cooperation & enforcementactions  (47%)Networking &events(3%)Cosmetics databases  (12%)Exchange of officials   (3%)Other supportingactivities  (12%)Objective I: Safety 
 
 
 
 
 
Although the external evaluation did not provide sufficient quantitative assessment, it has 
to  be  reported  that  the  implementation  of  such  joint  actions  was  considered  as  rather 
burdensome  by  national  authorities  participating,  requiring  for  the  coordination, 
management and reporting on the action significant resources from participating national 
authorities/the coordinating authority, which raised questions of efficiency over the last 
years. In response, under the Consumer Work Programme 2017, the financing modus of 
these joint  actions was changed  from  action  grants  to  procurement. This is  expected to 
also address the need to support more flexible and more strategic activities and a better 
communication of joint action results as well as the need to have as many national market 
surveillance authorities on board as possible. 

EUR 35.1 million  (37%)  of  the  funds  committed  under  the  Consumer  Programme 
between 2014 and 2017 were spent on activities related to  Objective II, which aims to 
improve consumers’ education, information and awareness of their rights, to develop the 
evidence  base  for  consumer  policy  and  to  provide  support  to  consumer  organisations, 
including taking into account the specific needs of vulnerable consumers. The following 
figure  shows  a  detailed  breakdown  of  the  funds  committed  under  Objective  II  of  the 
Consumer Programme between 2014-2017 by main activity. 

Figure 7: Breakdown of funds committed under Objective II by type of 
activity, 2014-2017 

In  the  four  years  under  consideration,  support  to  the  EU-level  consumer  organisation 
BEUC  totalled  EUR 5.9  million  (slightly  below  EUR 1.5  million  per  year),  equalling 
6.2% of total Programme costs committed.  

According  to  stakeholders,  outputs  and  results  appear  to  be  proportionate  to  spending 
levels. The Consumer Programme achieved the benefit of an improved representation of 
consumer interests at EU level (average score of 3.6 on a scale of 1 to 5). A consistent 
funding of BEUC has led to successful functioning of the organisation, which has grown 
and  found  other  sources  of  funding  (with  the  Commission's  core  grant  under  the 

48 

Objective II: Consumer Information & Education37% 
 
 
 
Consumer Programme constituting just over a third of the organisation’s total funding). 
No inefficiencies were identified. 

During the evaluation period, the amount committed for consumer rights and information 
campaigns was EUR 9 million, or 9.5% of total Programme costs. As media campaigns 
require  a  large  amount  of  resources,  the  costs  allocated  appear  in  principle  to  be 
proportionate  to  the  activities  undertaken  or  planned,  although  the  data  on  outputs  and 
results is too fragmented to draw detailed conclusions for the campaigns funded.  

Two  separate  evaluations  for  the  two  waves  of  the  consumer  credit  campaign  were 
conducted, which both found mixed results in terms of efficiency, mainly questioning the 
extent to which the right people (the target group) had been reached. 

Important  financial  resources  were  allocated  to  the  consumer  organisations  capacity 
building project “Consumer Champion” and the consumer education project “Consumer 
Classrooms”.  The  Consumer  Champion  project  has  ended  at  the  beginning  of  2018.  A 
new project supporting capacity building of consumer organisations will be implemented 
in 2019-2020, it will keep some elements of the Consumer Champion which were most 
successful, especially the local courses.   

The Consumer Classroom project as well ended in December 2018. The Commission is 
considering further activities in consumer education to be carried out. The efficiency of 
this project targeting primarily teachers is less easy to evaluate as it is  complex to assess 
the change in the knowledge of pupils and the value of the participation of the pupils and 
teachers in a European project supplementing a variety of  national efforts.   

Of  the  funds  committed  under  the  Consumer  Programme  between  2014  and  2017, 
EUR 13.0  million,  or  14%,  were  spent  on  activities  related  to  Objective  III.  The 
following figure shows a breakdown of the funds committed under Objective III of the 
Consumer Programme between 2014-2017 by main activity. 

Figure 8: Breakdown of funds committed under Objective III by type of 
activity, 2014-2017 

During  the  evaluation  period,  the  amount  committed  for  six  behavioural  studies  on 
consumer  decision-making  was  EUR 2.4  million,  equalling  2.5%  of  total  Programme 
costs.  Due  to  the  large  amount  of  resources  required  for  behavioural  research  and  the 
complexities of the testing involved, the  costs can be considered to  be proportionate to 
the activities conducted or planned.   

EUR 30.2  million,  or  31%  of  the  funds  committed  under  the  Consumer  Programme 
between 2014 and 2017, were spent on activities related to Objective IV. The following 

49 

Objective III: Rights & RedressBehavioural studies (18%)Other EU consumerstudies (14%)ODR Platform (23%)Communication on ODR/ADR (24%)Networking & events (6%)Consumer Summit(7%)Citizens'Energy Forum (0.4%)14%Other supporting activities (8%) 
 
 
 
figure  shows  a  detailed  breakdown  of  the  funds  committed  under  Objective  IV  of  the 
Consumer Programme between 2014-2017 by main activity. 

Figure 9: Breakdown of funds committed under Objective IV by type of 
activity, 2014-2017 

In the evaluation period, the amount committed for the ECC-Net was EUR 24.8 million, 
equalling 26.0% of total Programme costs.  The level of co-financing for ECCs is 50% in 
most Member States and goes up to 65% in some cases. 

The 2017 status review of the ECC-Net found that it had in many ways contributed to a 
higher  level  of  consumer  protection  in  the  internal  market,  and  confirmed  through 
stakeholder interviews that the costs for running the ECC appear to be adequate as well 
as “the added-value of ECCs in relation to their costs”. However, the status review noted 
that the level of achievement varied greatly between ECCs. 

Overall,  consumer  education  and  information  (including  the  evidence  base)  and 
enforcement  together  account  for  two  thirds  of  the  total  amount  committed  under  the 
Consumer  Programme  between  2014  and  2017,  in  line  with  their  key  importance  for  a 
welfare-enhancing consumer market. Stakeholders assessed that the distribution of funds 
among  the  four  Programme  areas  (product  safety,  consumer  education/information, 
consumer  rights  and  redress,  and  enforcement)  has  been  largely  justified  given  the 
benefits  achieved  (average  score  of  3.7  on  a  scale  of  1  to  5).  It  is  notable  that  the 
assessment diverged considerably by stakeholder group, with higher average assessments 
given  by  ECCs  and  ministries/national  authorities,  who  are  also  major  direct 
beneficiaries of Programme activities. 

Beyond considering the allocation by Programme area/objective, it is also of interest to 
analyse  the  allocation  of  funding  to  main  activities.  During  the  evaluation  period,  the 
activities that received the largest amount of funding (EUR 2 million or more) were: 

  European Consumer Centres Network (ECC-Net) – EUR 24.8 million; 
  EU consumer information/awareness raising campaigns – EUR 9.0 million; 
  Consumer scoreboards and surveys – EUR 8.9 million; 

50 

Objective IV: Enforcement31% 
 
 
 
  Joint  cooperation  and  enforcement  actions  in  the  area  of  non-food  consumer 

product safety – EUR 6.2 million; 

  Support to EU-level consumer organisations (BEUC) – EUR 6.0 million; 
  Consumer market studies – EUR 5.1 million; 
  EU consumer education resources (Consumer Classroom) – EUR 3.1 million; 
  Communication campaigns and actions on ADR/ODR  – EUR 3.1 million; 
  Online Dispute Resolution (ODR) Platform maintenance – EUR 3.0 million; 
  Rapid  Alert  System  for  dangerous  non-food  products  (RAPEX)  –  EUR  2.9 

million; 

  Behavioural studies – EUR 2.4 million; 
  Consumer  Protection  Cooperation  (CPC)  Network  (IT  tool  and  support  to 

enforcement coordination) – EUR 2.0 million. 

It  can,  therefore,  be  concluded  that  the  total  amount  allocated  to  the  ECC-Net  is  much 
higher than the support to public enforcement in the areas of consumer rights and product 
safety. The Commission finances 50% of the ECCs networks' activities, which is decisive 
for the activity and the very existence of the ECC-Net, at least according to the current 
model  of  co-funding.  The  2017  Status  Report  concluded  that  the  costs  for  running  the 
ECC-Net  are  proportionate  to  the  added  value  of  its  services  to  consumers.132  At  the 
same time, the ECCs are facing the challenge of ensuring a comparable service content 
and quality across the network.133 

Regarding  enforcement,  the  EU  provides  a  framework  for  enforcement  cooperation  as 
well  as  the  IT  tool  used  by  authorities  to  exchange  information  and  requests  to  take 
enforcement  measures.  For  the  CPC  Network  the  support  includes  the  design  of  up-to-
date  IT  tools  and  co-ordination  actions  (e.g.  sweeps,  meetings),  while  the  CPC  entities 
themselves are national enforcement authorities and hence no staff costs of the national 
administrations are covered.  

The funds allocated to the CPC Network have so far been modest (not all budgeted funds 
for CPC activities are taken up) compared to other activities funded under the programme 
(EUR 2.0 million in the period 2014 to 2017). As several stakeholders have stated, it is 
remarkable that so much enforcement cooperation and joint actions have been achieved 
nonetheless. The modest funding of the CPC Network has been partly preconditioned by 
the narrow basis for common actions under the current CPC Regulation.  

In  the  interviews  conducted  for  the  evaluation  of  the  programme,  the  most  mentioned 
factor contributing to low achievements of benefits with respect to enforcement in both 
the  consumer  law  and  product  safety  field  were  limited  staff/financial  resources  of 
authorities.  An  even  more  pronounced  situation  is  the  limited  capacity  of  consumer 
organisations in many Member States in spite of their importance for private enforcement 
of consumer law.  

Concerning the  funds allocated to  consumer information and awareness  campaigns and 
consumer education, the total amount committed in the period 2014 to 2017 (EUR 15.2 
million)  is  equivalent  to  EUR  3.75  million  per  year,  or  EUR  125 000  per  year  and 
country  covered.  Even  with  very  effective  measures  and  targeting  of  resources  on 

132 Status Report, p. 79 ff. 
133 Status Report, p. 79.  

51 

 
 
 
 
                                                           
specific Member States or issues, these resources may not allow for lasting impacts to be 
achieved  when  targeting  large  consumer  groups  or  teachers/pupils  across  Europe.  It 
could  be  reconsidered  in  the  future  whether  to  prioritize  consumer  information  and 
education to achieve the larger scope and more lasting impact.  

With  expenditures  under  the  Consumer  Programme  being  equivalent  to  less  than  5 
Eurocents  per  citizen  and  year,  there  is  room  for  improvement  in  terms  of  budgetary 
investment to further meet the challenges posed by the overall goal to reach a high level 
of consumer protection in  an internal  market  of more than 500 million citizens. This  is 
also confirmed by the external evaluation study, which shows that in spite of the slightly 
greater support provided by the Consumer Programme to the more recently acceded and 
southern  Member  States,  most  indicators  do  not  indicate  that  these  efforts  have  led  to 
tangible results in terms of increased convergence, confirming the limitations of what can 
be achieved with the resources currently allocated for this purpose. 

Regarding  the  design  of  the  Consumer  Programme,  several  aspects  were  considered  in 
detail: 

  The extent to which the actions/activities of the are well defined; 

  The extent to which the annual work programmes are transparent.  

The evaluation found no indication of major deficiencies in the definition of Consumer 
Programme  actions/activities.  The  second  aspect  is  more  subjective  in  character,  i.e.  it 
refers to the perception regarding transparency of the annual work programmes.  

Figure 10: Please indicate whether you agree or disagree with the following 
statements regarding the Consumer Programme 2014-20.  

Source:  Civic  Consulting,  stakeholder  interviews,  question  19.  N=109,  94,  101  (in  the  order  of  items  from  top  to 
bottom). Not included were interviewees who answered “don’t know” or who did not provide an assessment.  

Interviewees agreed the most with the following statements: The actions/activities of the 
Consumer  Programme  are  well-defined  (3.7),  the  annual  work  programmes  are 
transparent  and  the  Programme  is  well  structured  (both  3.6).  The  ECCs  and 
ministries/national authorities provided the highest assessments.  

About  two-thirds  of  stakeholders  interviewed  indicated  their  organisation  has  incurred 
costs  for  participating  in  specific  activities  or  applying  for  funding  under  the  current 

52 

3.73.63.612345The actions/activities of the ConsumerProgramme are well definedThe annual work programmes are transparentThe Consumer Programme is well structured (i.e.there are no major gaps, inconsistencies oroverlaps between the activities funded) 
 
 
 
consumer programmes (69%). Of those that incurred costs, a large majority found these 
costs to have been affordable given the benefits they received (see the following figure). 
For most activities, ministries/authorities and/or ECCs found them more affordable than 
consumer  organisations  (except  for  Consumer  Champion  and  the  complaints  database, 
which consumer organisations found on average more affordable).  

Figure 12: If you have answered 'Yes', please assess the extent to which 
the costs borne by your organisation have been affordable given the 
benefits you received – CP 2014-2020.  

Source: Civic Consulting, stakeholder interviews, question 27. N=36, 28, 54, 25, 21, 26, 19, 26, 19, 16, 20, 14 (in the 
order  of  items  from  top  to  bottom).  Not  included  were  interviewees  who  answered  “don’t  know”  or  who  did  not 
provide an assessment. Note: interviewees were asked to only assess the activities under the Consumer Programmes 
for which they incurred costs for participating or for applying for funding under the Consumer Programme, and to not 
consider costs due to specific legal obligations on Member States, e.g. related to participating in the RAPEX system, 
the ODR Platform, etc. 

ECC-Net,  joint  cooperation and enforcement  actions  in  the area of  non-food consumer 
product  safety  and  training  for  ECC-Net  received  the  highest  average  affordability 
assessments by interviewees (4.2, 4.1 and 4.0). The activity that was ranked the lowest in 
terms  of  affordability  was  European  Consumer  Complaints  Registration  System  and 
related  support  measures,  with  an  average  assessment  of  2.8,  reflecting  the  limited 
benefits received from this activity according to stakeholders. 

Finally, regarding the question as to whether significant differences in  costs or benefits 
between  Member  States  are  observed,  this  evaluation  did  not  find  evidence  in  this 
respect.  However,  the  existing  institutions  in  Member  States  matter  for  achieving  the 
benefits of the various activities financed under the Consumer Programme. Allowing for 
good  functioning  of  the  institutions  involved  in  the  challenging  task  of  protecting 
consumers is a crucial factor for enhancing the impact of many of the activities.  

53 

4.24.14.04.03.93.83.73.63.53.53.42.812345European Consumer Centres Network (ECC-Net)Joint cooperation and enforcement actions in the area ofnon-food consumer product safetyNetworking and eventsTraining for ECC-NetExchange of safety enforcement officials (GPSD)Training for enforcement officials and judiciary (E-Enforcement Academy)Exchange of enforcement officials (CPC)Joint actions for the enforcement of consumerprotection laws (CPC)EU consumer education resourcesCapacity building for consumer organisationsEU consumer information/awareness raising campaigns(e.g. on taking out credit, on energy efficiency)European Consumer Complaints Registration Systemand related support measures 
 
 
 
5.3 RELEVANCE 

This  section  is  examining  the  appropriateness  of  the  Programme's  objectives  to 
consumers' needs. In essence it covers the question as to what extent the objectives of the 
Programme have proven to be appropriate to consumer problems and needs, and more in 
particular to the specific needs of different consumer groups.  

Ministries,  national  authorities  and  ECCs  mostly  considered  the  objectives  and  the 
related  activities  to  have  been  appropriate  to  consumer  needs,  while  both  consumer 
organisations  and  business  associations  were  split  in  their  assessment,  with  most 
consumer organisations assessing the Programme to  be in  line with  their needs slightly 
lower, i.e. at 3.0. 

While a large majority of consumer organisations assessed the Programme positively in 
terms of relevance, a quarter of them (6 of 24 interviewed organisations) considered the 
objectives  and  related  activities  not  to  be  entirely  appropriate  to  address  consumers’ 
needs.  

Relevance to needs of specific consumer groups, such as vulnerable consumers: this was 
the  least  highly  assessed  item  by  stakeholders  The  average  score  of  3.2  is  close  to  the 
midpoint of the assessment scale, due to the fact that a majority of stakeholders provided 
a 'moderate' assessment of relevance. Again, consumer organisations provided the lowest 
assessment  (on  average  2.7).  It  was  remarked  that  activities  had  mainly  indirectly 
targeted  children  (notably  through  the  Consumer  Classroom),  while  other  categories  of 
consumers with special needs, such as the elderly population had been neglected. 

Thus it seems, from the qualitative evidence gathered for this evaluation, that addressing 
vulnerability  across  the  various  activities  of  the  Consumer  Programme  remains  a 
challenge,  and  except  for  certain  well-defined  areas,  such  as  activities  targeted  at  fuel 
poverty, more targeted actions would be needed.  

Relevance to the needs of the stakeholder community and to other consumer-relevant EU 
policies: all four objectives of the 2014-2020 Consumer Programme were considered to 
be  still  highly  relevant  by  the  interviewed  stakeholder  organisations.  “Enforcement  of 
consumer  rights”,  “product  safety”,  “consumer  rights  and  redress”  all  received  an 
average  assessment  of  4.4,  and  “consumer  education,  information  and  support  to 
consumer  organisations”  received  an  average  assessment  of  4.3.  ECC  interviewees 
tended to provide the highest relevance assessments for all four objectives.   

With  markets  in  some  sectors  evolving  at  a  rapid  pace,  evidence  gained  points  to  an 
increased  need  to  adapt  the  Programme's  objectives  linked  to  the  enforcement  of 
consumer rights. 

Emergence of new needs that might  necessitate an adjustment of objectives:  evaluation 
respondents  were  asked  to  judge  how  well  adapted  they  considered  the  Programme's 
interventions  to  economic,  technological,  scientific,  social,  political  or  environmental 
advances.  Over  two-thirds  of  interviewees  indicated  that  new  needs  have  emerged  that 
necessitate an adjustment of the Consumer Programme with respect to each of the four 
Programme  areas.  The  Programme  areas  for  which  the  most  interviewees  indicated  a 
need  for  adjustment  were  “consumer  rights  and  redress”  (78%  of  interviewees)  and 
“enforcement  of  consumer  rights”  (77%  of  interviewees).  For  the  product  safety  and 

54 

 
 
 
consumer  information  and  education  parts  of  the  Programme,  over  two-thirds  of 
interviewees (71% and 68%, respectively) indicated that this is the case. 

The most commonly cited new needs related to  the challenges of keeping up with  new 
innovations  in  products,  services,  and  markets.  Many  mentioned  increasingly  complex 
value chains  and the connected risks for consumer harm originating from traders based 
outside the territory of the EU. The necessity of enhanced cooperation with enforcement 
authorities in big trading partners, such as US and China was also emphasized. 

Also  mentioned  was  the  need  for  new  approaches  to  deal  with  connected  products  and 
the  Internet  of  Things  as  well  as  product  safety  concerns  related  to  3D  printing. 
Evaluation  respondents  highlighted  challenges  related  to  online  platforms  and  data 
protection  as  well  as  adapting  to  new  sales  channels  and  marketing  techniques,  and 
suggested  that  specifically  targeted  consumer  education  and/or  capacity  building 
activities  for  consumer  organisations  would  be  needed  in  these  areas.  A  cross-cutting 
theme was also the need to improve redress mechanisms for consumers, especially in a 
cross-border context, including the need for collective redress mechanisms, with multiple 
interviewees citing the recent Volkswagen scandal as an example. 

There  is,  therefore,  considerable  consensus  that  new  needs  have  emerged  due  to 
economic,  technological,  scientific,  social,  political  or  environmental  advances,  which 
will  have  to  be  considered  when  designing  actions  and  activities  under  any  new 
Programme. This is also underpinned by recent large-scale issues for consumers created 
by  problems  such  as  the  "Diesel-gate",  dual  quality  standards  of  foodstuff,  or  massive 
flight cancellations.  

New  programme  activities  will  also  have  to  take  into  account  the  impact  of  further 
digitalisation  of  consumer  markets  on  consumer  protection,  in  particular  to  ensure  the 
equal treatment of all consumers across the Single Market. 

 The  feedback  from  stakeholders  shows  that  the  four  objectives  and  priorities  of  the 
Consumer Programme 2014-2020 are still relevant and meet key consumer needs. 

5.4 COHERENCE 

This section analyses how and if different  actions within the Consumer Programme are 
coherent  and  work  together  and  to  what  extent  have  the  priorities  of  the  Consumer 
Programme produced synergies, focus and coherence between the funded actions which 
improve the overall performance of the programme. 

As regards overlaps and inconsistencies, the Consumer Programme 2014-2020 minimises 
them  by  design  through  the  use  of  a  hierarchical  (or  'tree')  structure:  four  specific 
objectives,  which  are  linked  to  eleven  specific  actions,  under  which  a  total  of 
approximately  30  main  activities  are  funded.  No  overlaps  or  inconsistencies  were 
identified in  the framework of the analysis of the implemented actions/activities by the 
evaluation study. The feedback from stakeholders corroborated this.  

The  evaluation  study  found  that  when  analysing  the  coherence  between  objectives  and 
actions, no gaps appear to exist – all elements of the objectives are reflected in the related 
actions. On the other hand, when analysing the coherence between actions and the main 
activities funded certain gaps were identified at this stage of Programme implementation: 

55 

 
 
 
 
1.  In relation to Action 2 (Coordination of market surveillance and enforcement actions 
on  product  safety,  and  actions  to  improve  consumer  services  safety)  of  the  
“Objective I – Safety” there was so far no funding of activities that specifically focus 
on services safety; 

2.  In  relation  to  Action  6  (Enhancing  the  transparency  of  consumer  markets  and 
consumer information) of the  “Objective II – Consumer information and education, 
and  support  to  consumer  organisations”  there  was  so  far  limited  implementation  of 
activities  that  enhance  the  transparency  of  consumer  markets  and  consumer 
information, to help them compare not only prices, but also quality and sustainability 
of goods and services; 

3.  In relation to Action 7 (Enhancing consumer education as a life-long process with a 
particular  focus  on  vulnerable  consumers)  of  the  “Objective  II  –  Consumer 
information  and  education,  and  support  to  consumer  organisations”  the  focus  on 
consumer  education  targeting  vulnerable  consumers  has  so  far  been  limited  to  one 
group only (children, through the Consumer Classroom)134; 

4.  In  relation  to  Action  9  (Facilitating  access  to  dispute  resolution  mechanisms  for 
consumers,  including  through  a  Union-wide  online  system  and  the  networking  of 
national  alternative  dispute  resolution  entities)  of  the    “Objective  III  –  Rights  and 
redress” no activities regarding networking of national alternative dispute resolution 
entities took place so far135; 

As regards the actions of Objective IV, no potential gaps have been identified.  

In  spite  of  these  potential  gaps,  all  levels  of  the  intervention  (objectives,  actions, 
activities)  are  consistent  and  coherent.  This  is  the  general  view  of  stakeholders,  which 
largely  consider  the  Consumer  Programme  to  be  well  structured  (no  major  gaps, 
inconsistencies or overlaps between the activities funded).  

The  2014-2020  Consumer  Programme  was  considered  by  interviewees  to  be  largely 
coherent  with  EU  consumer  policy  in  general  as  set  out  in  Consumer  Agenda  and  the 
Commission’s  communications  on  sectorial  topics  with  the  consumer  interests  therein 
(with average assessments of 3.8 on a scale of 1 to 5). For instance, programme actions 
proved  to  be  coherent  with  Retail  financial  services,  services  of  general  interest, 
passenger rights, and gas and electricity. Consistently, stakeholders reported on the use of 
evidence  bas  gathered  under  eh  programme  (market  studies,  behavioural  studies, 
consumer  scoreboards,  etc.)  for  DSM-Digital  Single  Market  initiatives  and  in  some 
respect with the EU Circular economy package. As for the latter, due to direct connection 
to  sustainable  consumption  and  its  increasing  importance  and  visibility,  further 
enhancement  of  synergies  with  consumer  policies  should  be  pursued.  The  potential 
synergies with other programmes, such as LIFE, Rights, Equality and Citizenship (REC), 
and Connecting Europe Facility are identified. 

134 However, the Awareness Raising campaign on Energy Efficiency prepared in 2017 and  launched in 
2018 in CZ, RO, EL and PL addresses this gap by providing a.o. information targeting consumer groups in 
situations of energy poverty and/or poverty. 
135 However in June 2018, the Commission will host the ADR Assembly 2018, which will bring together 
representatives of all EU certified ADR entities, ADR compete authorities, ODR contact points, European 
Consumer Centres, consumer organisations, business associations, key retailers and other ADR/ODR 
stakeholders. 

56 

 
 
 
                                                           
5.5 EU ADDED VALUE, COMPLEMENTARITY, SUSTAINABILITY 

This  added value of the  EU intervention is  confirmed by the views  of 89% of national 
stakeholders who considered that the same consumer policy and protection results would 
not have been achieved in their countries via initiatives funded only at national/regional 
level,  and  without  the  EU  interventions  through  the  2014-2020  Consumer  Programme.  
In  addition,  88%  of  national  stakeholders  considered  the  programme  actions  had  a 
moderate  or  great  impact  on  the  development  of  national  consumer-related  policies 
(average rating of 3.7. out of 5). ECCs, ministries/ authorities and business associations 
saw  a  more  pronounced  impact,  than  consumer  organisations;  none  of  the  stakeholders 
saw no impact at all (Table below).  

Table  10:  In  your  view,  to  what  extent  have  the  Consumer  Programmes’  actions 
impacted  on  the  development  of  national  policies  in  the  consumer  field?  CP  2014-
2020. Average assessments on a scale of 1 (Not at all) to 5 (To a great extent) 

Stakeholder type 

1 (Not at all)   2 

Business association 

Consumer organisation 

European 
Centre 

Consumer 

Ministry  or  national 
authority 

Other 

All stakeholders 

-- 

-- 

-- 

-- 

-- 

-- 

3 

1 

10 

4 

3 

7 

(To 

5 
great 
extent) 
1 

3 

3 

13 

5 

17 

21 

3 

3 

8 

1 

1 

7 

1 

3 

1 

13 

34 

47 

18 

a 

Average 
assessment 

3.7 

3.2 

4.0 

3.7 

3.5 

3.6 

Sources:  Civic  Consulting,  stakeholder  interviews,  question  21.  N=112.  Not  included 
were interviewees who answered “don’t know” or who did not provide an assessment. 

Almost  all  interviewees  who  expressed  an  opinion  considered  that  the  EU  intervention 
through  the  Consumer  Programmes  provided  an  added  value  beyond  what  could  have 
been  achieved  by  their  respective  Member  States  acting  alone.  For  example,  evidence 
from follow-up analyses of sweeps shows that compliance with EU consumer law after 
sweeps  are    considerably  higher  than  before.  The  impact  of  joint  actions  bringing 
business  practices  into  conformity  with  EU  law  is  significant.  Training  of  national 
enforcement officials is a prerequisite to enforcing EU consumer law.  

The  ECC-Net  assistance  to  consumers  with  cross-border  purchase  problems  help  make 
the single market work for consumers and in collecting data on cross border trade issues 

57 

 
 
 
 
for  single  market  and  consumer  policy  development.  National  action  to  achieve  this  is 
not undertaken by any Member State.  

Without funding from the Consumer Programme the following actions funded under the 
Consumer Programme are certain or likely to cease  

a) Objective I – Product Safety :  

-  RAPEX  coordination  function  and  joint  product  safety  actions  would  not  take  place 
without EU funding as this burden is unlikely to be taken over by any single MS.  

b) Objective II    

- evidence base: without an evidence base EU policy development and compliance with 
better regulation would not be possible. National studies would fill this gap only to a very 
limited extent and only in the limited number of Member States who dispose of research 
funding  and  capacity. Moreover, no or little comparability  of information/data between 
Member States would be possible without an EU active role.  

- Operational grant for EU level consumer organisation: stopping this action would mean 
that  a  coordinated  consumer  voice  will  not  be  heard  at  EU  level,  that  consumers  from 
most Member States would not be represented at EU level and that their interests are less 
likely  to  be  taken  into  account  in  many  fields  of  EU  level  policymaking  affecting 
consumers,  ranging  from  consumer  policy  to  health,  energy,  environment,  food  safety, 
trade etc. EU level consumer representation would then be exclusively of consumers in 
countries with  a strong consumer movement  and a function of the financial and human 
resources  such  national  organisations  can  afford  to  dedicate  to  EU  level  consumer 
representation.  More  importantly,  stopping  this  operational  grant  would  create  an  even 
stronger imbalance in  the representation  of consumer interests as  compared to  business 
interests.  

-  Capacity  building  :  Member  States  with  higher  levels  of  skills  and  professionalism 
expect  the  EU  to  take  on  this  role  and  are  unlikely  to  provide  this  kind  of  systematic 
support  to  authorities  and  organisations  in  all  of  the  other  Member  States,  beyond 
occasional bilateral exchanges.   

- EU level  awareness  raising of (cross-border) consumer rights: information and advice 
about  consumer  rights  is  available  at  national  level  in  all  Member  States  for  national 
consumers, but mostly does not cover cross-border perspective of EU awareness raising 
campaigns.  Consumer  rights  awareness  raising  campaigns  are  overall  a  useful  tool  to 
illustrate the benefits of the EU for its citizens in their daily lives. Not undertaking such 
action  would  be  a  missed  opportunity  to  positively  influence  public  opinion  about  the 
EU.  

c) Objective III 

Without  studies,  surveys,  and  other  actions  aimed  at  informing  policy  development, 
compliance with Better Regulation principles would not be possible.  

58 

 
 
 
Funding  for  ODR  platform  functioning  and  improvement  is  an  obligation  upon  the 
Commission  and  the  platform  cannot  function  effectively  without  supporting  actions 
promoting ADR.  

d) Objective IV 

Without  EU  enforcement  cooperation 
interventions,  national  governments  and 
enforcement authorities would need to put more resources into domestic enforcement, or 
not  enforce  these  rules  for  lack  of  resources,  or  enforce  them  in  different  ways  to  the 
detriment of legal certainty and harmonisation in the Single Market.  

Several stakeholders expressed the view that a withdrawal of the EU support for the ECC 
network  would  mean  its  work  in  their  country  would  be  discontinued,  given  financial 
constraints and pressures of policy prioritisation at the national level. The overall value 
and effectiveness of the network would significantly decrease in case several MEMBER 
STATES would withdraw. 

The following actions could be undertaken by the MEMBER STATES, but would focus 
on national priorities. In practice many MEMBER STATES would not have the funding 
and, thus, any action at all would, therefore, be unlikely to be taken.   

Building  and  facilitating  exchange  of  online  consumer  education  and  information 
resources  for  use  by  teachers  and  schools  in  the  MEMBER  STATES  and  by  national 
consumer  authorities  and  organisations  is  an  activity  that  exists  in  some  MEMBER 
STATES and will be undertaken for national audiences, but that is and will likely not be 
undertaken  by  other  MEMBER  STATES.  The  necessity  of  such  resources  and  efforts 
will increase with  the need to  build consumer trust  for example in  data protection and 
artificial intelligence  

Intermittent  and/or  decreasing  project  funding  at  the  national  level  and  the  absence  of 
project  funding  at  EU  level  for  national  consumer  organisations  (which  was  available 
under  the  previous  Consumer  Programme)  has  meant  that  many  national  consumer 
organisations  without  a  strong  membership  base  have  seen  their  level  of  activity  since 
2007  stagnate  or  decrease.  Efforts  under  the  Programme  to  increase  their  level  of 
professionalism  and  skills  have  given  positive  results,  insofar  as  they  were  able  to 
employ permanent staff. Its impact will only be ensured if that staff can be retained.  

Discontinuation  of  both  support  for  EU  level  consumer  organisations,  EU  capacity 
building  for  national  consumer  organisations  and  EU  level  consumer  education, 
information  and  awareness  raising  is  likely  to  lead  to  a  "dual  quality"  in  consumer 
representation,  education  and  information  and  might  well  risk  creating  negative 
perceptions of the EU. 

It  can  be  surely  stated  that,  the  Programme  complements  national  policies  through 
research  and  policy  development,  enforcement  coordination  and  cooperation, 
coordination of market surveillance and enforcement actions on product safety  and the 
ODR platform. 

59 

 
 
 
This complementarity is confirmed by stakeholders (average agreement of 3.3 on a scale 
of 5); they also indicated that complementarity should be improved by dedicating more 
attention to early detection of new marketing practices and exchange of experiences and 
best practices in national policy development. 

Moreover,  the  Programme    supplements  the  policies  of  some  of  the  Member  States  in 
areas  where  such  Member  States  have  no  or  a  very  limited  level  of  activity,  such  as 
capacity  building,  awareness  raising  and  consumer  education;  these  actions  are  either 
focused on such Member States to aim help bring consumers in such Member States to a 
similar level of awareness of consumer rights or consumer education as in other Member 
States,  or  build  EU-level  resources  that  are  more  intensively  used  by  target  groups  in 
certain  Member  States,  such  as  Consumer  Classroom,  capacity  building  and  training 
actions.  

Finally,  the  programme  monitors  national  policies  through  studies  and  surveys  such  as 
consumer scoreboards, stakeholder networks, transposition-checks.  

Stakeholders considered the effects of the Consumer Programme 2014-2020 to be likely 
to  last  after  the  end  of  the  Programme,  in  particular  in  the  area  of  product  safety, 
enforcement and consumer rights and redress.  Materials produced and processes set up 
with  resources  from  the  programme  would  provide  a  starting  point  for  further  national 
activities. 

However, stakeholders also considered that to ensure a continued effect, most actions of 
the  Programme  require  continued  support  beyond  2020.  It  is  essential  to  consolidate 
research,  enforcement  and  data-gathering  networks  and  structures  and  enable  them  to 
address  newly  emerging  concerns,  in  particular  for  actions  based  on  legislative 
obligations (ODR platfrom, CPC) or provide input into market monitoring activities and 
legislative work (ECC, ECCG, CPN, CMEG).  

The following effects would materialise if the funding were to be withdrawn: 

a) Objective I – product safety  

Withdrawal  of  funding  for  RAPEX  and  of  updating/evaluating  the  EU  legislative 
framework (i.e. with no market studies) would have an immediate effect on the quality of 
monitoring of product  safety and mid-term  effect on the effectiveness  of the legislative 
framework. 

b) Objective II  

Withdrawal  of  evidence  base  actions  would  negatively  affect  foresight  activity 
immediately and policy making within 2 years. Also, withdrawal of the operational grant 
for EU level consumer organisations would lead to an immediate reduction in the level of 
activity of EU level consumer organisation(s).   

It is generally recognized that education and information activities need to be maintained 
to ensure continued impact, otherwise any negative impact would be apparent even at a 
short time (in few years)... 

60 

 
 
 
 
c) Objective III  

-  The  quality  of  EU  policy  making  would  be  lowered  if  funding  for  market  and 
behavioural research to identify market failures, consumer detriment and policy remedies 
would be discontinued.  Such research is not conducted in a systematic way in a majority 
of the Member States for lack of  human and financial  resources and skills, and where it 
is  conducted  (Germany,  Denmark,  France,  The  Netherlands,  the  United  Kingdom)  it  is 
undertaken only or mainly to monitor national markets without a comparative or cross-
border perspective.  

d) Objective IV  

The  positive  effects  from  successful  activities  under  the  enforcement  objective  of  the 
current  Consumer  Programme,  such  as  better  compliance  of  businesses  with  EU 
consumer  laws  and  enhanced  consumer  confidence,  may  be  expected  to  last  for  some 
time. But newly emerging issues or scandals have the potential to undermine consumer 
trust faster than it can be rebuilt. And the opportunity and need for joint action is likely to 
increase  with  the  digitalisation  and  increased  cross-border  nature  of  consumer  markets. 
Therefore  continuous  joint  enforcement  action  at  EU  level  and  cross-border  consumer 
assistance will be more necessary in the future than the past.  

Overall,  it  is  unlikely  that  many  of  the  activities  currently  carried  out  within  the 
framework of the Consumer Programme will be readily taken over by Member States or 
by market actors in the absence of continuous Union commitment and support for these 
activities. Several stakeholders underscored the low priority accorded to consumer policy 
at  the  national  level  and  the  decisive  effect  that  the  commitments  under  the  EU 
Consumer Programme exerts for strengthening consumer law enforcement at the national 
level.  

Seen  from  this  perspective,  the  infrastructure  for  coordinated  enforcement  provided  by 
the  CPC  Network,  RAPEX  and  the  Consumer  Safety  Netowrk  appears  indispensable. 
Whereas  some  well-functioning  bilateral  or  regional  forms  of  cooperation  would 
probably  continue  to  exist,  fully  developed  frameworks  for  EU-wide  enforcement 
cooperation without the leading and coordinating role of the Commission are not likely 
to persist.  

5.6 SIMPLIFICATION AND BURDEN REDUCTION 

This  chapter  looks  into  the  possibility  of  the  simplification  and  burden  reduction  in 
managing the funding both from the Commission’s and beneficiaries point of view. 

The  programme  management  has  been  somehow  complicated  by  the  fact  that  the 
Consumer policy directorate has been transferred to the DG Justice and Consumers from 
DG SANTE in  the Commission’s reorganisation of 2015 while some funding activities 
remained under the responsibility of DG SANTE or have been transferred to DG GROW. 
This has been the case for the management of the scientific advice on consumer health 
and the database on cosmetics under Objective  I of the Consumer Programme. Sharing 
the programmes’ funding between different DGs and policies on the other hand could be 

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the  simplification  measure  provided  there  is  a  good  governance  and  decision  making 
structure. 

The  consumer  programme  does  not  fund  the  functioning  of  the  national  consumer 
organisations  and their projects,  which  would be  the main object  for the  administrative 
burden and complexity (the major beneficiaries of funding are consortia that are awarded 
the  contracts  under  the  competitive  procurement  procedures).  Under  the  Consumer 
programme, the number of grants awarded and their amounts are rather small (not more 
than 40 grants with the average value of EUR 250 000). The tool used by CHAFEA is 
the  Grant  Management  tools  of  the  Research  family  DGs  which  has  been  designed  for 
the  grants  of  significant  value  and  for  large  consortium.  This  is  a  complex  IT  tool 
designed  for  all  stages  of  the  grant  management  –  application,  contracting,  and  project 
management  and  reporting.  It  caters  for  the  big  number  of  applications,  competitive 
selection, etc. It requires specialist knowledge for both the beneficiaries and CHAFEA’s 
staff.  

The  grants  under  the  Consumer  programme  are  awarded  to  known  and  pre-selected 
beneficiaries (ECC centres and a single European Consumer organisation) with some of 
them having limited resources to master this complex tool. Hence, it is to be considered 
whether, in order to achieve further simplification, a less complex IT tool should not be 
introduced aligned more to the specificities of these grants and beneficiaries.  

A  less  complex  financing  mechanism  could  be  envisaged  for  funding  enforcement 
cooperation.  The  current  funding  model  and  approach  does  not  gather  enough  funding 
requests from the national enforcement authorities. While this could be also the result of 
resources  issue  and  priorities,  more  flexible  arrangement,  including  the  funding  of  the 
staff  costs,  could  prove  to  be  more  effective  as  far  as  cross-border  enforcement 
cooperation actions are concerned.    

To  further  explore  potential  inefficiencies  in  programme  design,  management  and 
delivery,  regarding  the  scope  for  simplification  in  a  future  Consumer  Programme,  the 
highest  proportion  of  interviewees  saw  a  potential  for  simplification  regarding 
application procedures (59%), reporting requirements (54%) and a slightly lower number 
considered  that  programme  management  (47%)  and  delivery  mechanisms  (44%)  as 
summarised in the following figure.  

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Figure  11:  Do  you  see  any  scope  for  simplification  in  a  possible  new 
Consumer Programme?  

Source:  Civic  Consulting,  stakeholder  interviews,  question  24.  N=74,  68,  62,  62  (in  the  order  of  items  from  top  to 
bottom). Not included were interviewees who answered “don’t know” or who did not provide an assessment. 

Specific issues raised included: 

  The application system for grants  managed by CHAFEA (which was developed for 
managing much larger grants under the Horizon2020 Programme) is considered to be 
too complicated for the amounts involved; 

  The duration of ECC grants on an annual basis is considered to be too short a period 

for the administrative burden involved; 

  The  grant  reporting  requirements  were  considered  in  some  cases  to  be  overly 

complex and burdensome; 

The re-imbursement of travel costs regarding the exchange of officials was considered to 
be too late, as advance financing was not always available in authorities' budgets, thereby 
reducing  the  number  of  participants  in  such  exchanges,  especially  from  less  well-
resourced  authorities.  Significant  efforts  have  already  been  made  regarding  the 
simplification  of  procedures.  For  example,  the  model  for  the  allocation  of  funding  to 
national ECCs was recently reformed, replacing a system of annual grants with so called 
‘Framework Partnership Agreements’ for consecutive periods of three years. This change 
is expected to be a step towards increasing cost-efficiency as it reduces the administrative 
costs and provides better opportunities for long-term planning of activities.  

It  should  also  be  emphasised  that  certain  requirements  originate  in  the  EU  Financial 
Regulation  and  the  related  Rules  of  Application  which  limits  the  scope  for  changes. 
There might be potential for further reduction of administrative burdens in the choice of 
procedures,  and  by  combining  several  activities  into  single  framework  contracts,  with 
higher budgets and longer durations that should be explored. The Consumer Programme 
2014-2020 funds about 30 separate activities, in some cases the individual disbursements 
being  as  low  as  several  thousands  Euro.  This  in  particular  true  for  the  scheme  for  the 
exchange of officials. 

63 

59%54%47%44%41%46%53%56%Application proceduresReporting requirementsProgramme managementDelivery mechanismsYesNo 
 
 
 
 
 
Feedback  from  stakeholders  stressed  the  need  for  strong  coordination  between  the 
Commission  services  and  the  executive  agency  CHAFEA  that  was  entrusted  with  the 
management  of  part  of  the  Consumer  programme.  Important  efforts  to  improve 
coordination  are  being  made  already,  however  an  ongoing  evaluation  of  the  agency 
should  provide  additional  insights  in  how  information  exchange  and  coordination 
procedures can be strengthened, where needed.  

6. 

CONCLUSIONS 

The  midterm  evaluation  of  the  Programme  shows  a  general satisfaction  of  the 
stakeholders  in  terms  of  relevance  and  effectiveness  of  the  activities.  According  to  the 
interim  results,  highest  scores  in  terms  of  effectiveness  were  provided  regarding  the 
following  actions  funded  by  the  programme:  exchange  of  enforcement  officials, E-
enforcement  academy  (training  programme  for  enforcement  agencies),  and  support  to 
BEUC,  the  European  Consumer  Centres,  the  RAPEX  system,  and  funding  of 
stakeholders events or other activities that foster networking.  

Where  lower  levels  of  achievements  in  effectiveness  are  reported,  the  reasons  and 
influencing  factors  seem  to  relate  mostly  to new  market  challenges  driven  by  fast  and 
often  unpredictable  societal  and  technological  changes.  In  addition,  there  are  specific 
limitations  in  the  Member  States  that  affect  an  optimal  uptake,  such  as  constraints  on 
staff/financial  resources  as  well  as  in  some  cases  the  skills  of  NGOs  or  authorities. 
Finally  the  production  of  evidence  (studies,  scoreboard  etc.)  is  widely  accepted  as  an 
effective  instrument;  however  question  marks  remain  regarding  the  timeline  of  studies 
compared to the needs of the policy. 

Comparing  the  value  of  actions  funded  and  benefits  received,  it  is  confirmed  that  the 
most  efficient  was  the  funding  of  the  European  Consumer  Centres,  the  EU  wide 
consumer  organisation  BEUC  and  the  actions  by  the  enforcement  authorities.  Less 
efficient  were  consumer  information  and  education  actions  and  awareness  raising 
activities  as  it  is  considered  that  the  modest  amounts  spent  might  have  a  very  limited 
impact and produce low benefits, which could warrant exploring other forms of funding 
or redesigning the activities and if this fails possibly diverting this expenditure to other 
actions.  

Overall the objectives and priorities of the Consumer Programme are assessed as being 
still  fully  relevant  and  should  be  continued.  Additional  priorities  could  be  given  to 
sustainable  consumption,  to  activities  that  contribute  to  a  uniform  and  high  level  of 
consumer protection throughout the EU, including the support of consumer organisations 
in their role as consumer watchdogs, separately or jointly with the Member States. 

In terms of coherence, there seems to be little overlaps with other EU policies and other 
EU  programmes,  but  a  potential  for  increasing  synergies  with  other  programmes  for 
instance  in  funding  the  actions  of  market  surveillance  authorities,  financing  and 
procuring studies, especially in the area of circular and green economy or digitalisation 
of markets.  

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Regarding programme activities administrated/implemented by CHAFEA, there seems to 
be  room  for  improvement  regarding  administrative  burdens  related  to  the  programme 
delivery  and  also  scope  for  simplification,  including  as  regards  grants  for  joint  actions 
and  exchange  of  officials  as  well  regarding  the  IT  tools  applied  to  awarding  and 
managing the grants. 

Suggestions  for  changes  to  the  programme  include  the  need  for  more  flexibility  (i.e.  a 
less  prescriptive  programme),a  wider  variety  of  financing  instruments  used  (projects  of 
the  consumer  organisations,  projects  run  by  partnerships  or  the  consumer  organisations 
and  public  authorities),  improved  responsiveness  to  the  emerging  issues,  including  the 
funding  of  projects  of  international  organisations  and  projects  with  third  countries  
(especially in the area of administrative cooperation and enforcement). 

Most stakeholders flagged the need to reinforce the support to  certain types of activities, 
such  as  the  development  of  relevant  market  information  for  enforcement  purposes,  the 
development of adequate testing facilities, skills and expertise for the capacity building 
of the enforcement authorities as well  as the  consumer organisations who would act  as 
the  qualified  entities  under  the  Directive  on  representative  actions  for  the  protection  of 
the collective interests of consumers.  

National  consumer  organisations  could  be  more  involved  in  information  activities  and 
ways of improving their longer term sustainability could be explored. 

National  and/or  regional  consumer  policy  has  over  the  past  ten  years  to  a  large  extent 
been  driven  by  EU  legislative,  enforcement  and  surveillance  activity,  as  well  as 
consumer  and  market  research,  awareness  raising  and  capacity  building,  education  and 
training,  and  best  practice  networking  initiatives  and  activities  supported  by  the 
Consumer programme.  Without the Consumer Programme funding the consumer issues, 
notably  in  digital  markets,  platform  economy  and  enhancement  of  consumer  redress 
would not  have been addressed.  In many  countries, and in  most, if not all,  of the more 
recent  Member  States,  and  where  consumer  policy  has  become  a  self-standing  policy 
mainly as a consequence of EU membership, activities supported by the programme have 
been the main driver of policy development and enforcement. 

65