CASP 2020, Coordinated activities on the safety of products : online market surveillance : protecting European consumers together : final report.
Date: 2021-11-10
Institutions: Directorate-General for Justice and Consumers
Subjects: European Economic Area, European Union, consumer protection, digital single market, market supervision, product safety, report

CASP 2020 

Coordinated Activities on the Safety of Products
Online market  
surveillance
Final Report

PROTECTING  
European consumers 
together

Justice  
and Consumers

Contents

List of abbreviations  
Executive summary 

Content of the activity 

  Main results and conclusions 

Recommendations 

PART 1
1. Online Market Surveillance activity overview 

1.1  Introduction and objectives 
  1.2  Overview of participating MSAs 
2.  Summary of main activities and outcomes 
  2.1 CASP 2020 OMS approach 
  2.2 Scoping of the activity 
  2.3 Selection of key challenges 
  2.4 Identifying solutions 
  2.5 Co-development of solutions 
3.  Conclusions and recommendations 

3.1  General conclusions 

  3.2  Recommendations 
  3.3  Lessons learnt 

PART 2
1.  What is CASP?  
  1.1 Roles and responsibilities 
  1.2 Timeline of the project 
2.  Overview of the HA approach 
3.  Communication activities 

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CASP 2020 - Online market surveillance 
List of abbreviations

AI

CASP

Artificial intelligence

Coordinated Activities on the Safety of Products 

DG JUST

Directorate-General for Justice and Consumers of the European Commission 

EAN

EC

EEA

EO

EU

HA

KoM

MS

MSA

OMS

PSA

European Article Number

European Commission

European Economic Area 

Economic operator

European Union 

Horizontal activity 

Kick-off meeting

Member State(s)

Market surveillance authority

Online market surveillance 

Product-specific activity

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CASP 2020 - Online market surveillanceExecutive summary 

Content of the activity

The  Coordinated  Activities  on  the  Safety  of  Products 
(CASP) projects enable all market surveillance authorities 
(MSAs) from European Union (EU) / European Economic 
Area  (EEA)  countries  to  cooperate  in  reinforcing  the 
safety of products placed on the European single market. 

Prior  to  launching  the  project,  the  Directorate-General 
for Justice and Consumers of the European Commission 
(DG  JUST)  coordinated  a  priority  setting  exercise  to 
gather  input  from  Member  States  (MS)  regarding  the 

Main results and conclusions 

In  a  joint  effort,  the  participating  MSAs,  DG  JUST,  and 
the  Contractor,  via  its  commissioned  expert,  mapped 
relevant  online  market  surveillance  related  challenges 
and  explored  four  of  them  (those  deemed  most 
important) in more detail:

•  Sampling  (including  mystery  shopping).  With 
the  increased  volume  of  e-commerce,  MSAs  find  it 
difficult  to  locate  and  collect  those  samples  most 
likely to pose risks to consumers from online sources. 
In  addition,  some  MSAs  cannot  perform  mystery 
shopping due to restrictive internal rules or a lack of 
resources. 

•	 Identification	 of	 economic	 operators	 (EOs).  It 
might  be  difficult  for  MSAs  to  identify  and  contact 
EOs  that  are  selling  via  online  platforms  as  their 
contact details might be missing. 

•  New platforms. New platforms like social networks 
have  become  an  integral  part  of  the  e-commerce 
ecosystem  as  they  facilitate  the  online  selling  and 
buying  of  consumer  products.  MSAs  might  need  a 
strategy on how to deal with these new actors. 

•  Reappearance of products. If a dangerous product 
is  banned  from  an  online  platform  (for  instance, 
based  on  a  notification  from  Safety  Gate),  it  can 
easily reappear on the same platform or on another 
one. 

The  MSAs  discussed  these  challenges  in  detail  and 
developed  four  tools  based  on  existing  best  practices, 
their own experiences and joint brainstorming exercises 
designed to help overcome them.

•  Repository  of  digital  tools  used  for  market 
surveillance.  The  repository  maps  existing  digital 
tools  used  for  online  market  surveillance  purposes. 
The tools are described in detail and practical advice 

choice  of  products  and  activities  to  be  included  in  the 
coordinated  activities.  Among  others,  Online  market 
surveillance (OMS) was identified as a priority.

The  CASP  2020  OMS  horizontal  activity  (HA)  focused 
on identifying and exploring the main challenges faced 
when  performing  online  market  surveillance  and  also 
on creating hands-on tools and solutions with MSAs to 
overcome these.

is  provided  in  order  to  enable  MSAs  to  use  them 
effectively. 

•  Best practice repository for mystery shopping. 
The  tool  describes  mystery  shopping,  the  minimum 
elements needed to enable MSAs to introduce it and 
a  series  of  best  practices  collected  throughout  the 
activity. The tool aims to be a reference point for MSAs 
that  have  not  yet  introduced  mystery  shopping  or 
want to improve their mystery shopping capabilities. 
•  Protocol for cooperation with social networks. 
The  tool  provides  guidance  to  MSAs  so  that  they 
can  start  discussions  with  the  newest  members  of 
the  e-commerce  ecosystem  –  social  networks  that 
facilitate  the  sales  of  consumer  products.  The  tool 
lays  down  the  general  guidelines  for  cooperation, 
designates  areas  for  voluntary  commitment  for 
social networks and advises authorities on contacting 
and negotiating with these actors. 

•  Data exchange between MSAs and e-commerce 
platforms.  The  tool  provides  a  roadmap  on  how 
to set up a data exchange and messaging between 
MSAs and e-commerce platforms in order to enable 
MSAs to inquire about dangerous products and take 
action if needed. 

These tools are included in the CASP 2020 OMS guidance 
document, which can be used by all EU/EEA MSAs. 

4

CASP 2020 - Online market surveillance•  Join  the  Product  Safety  Pledge2.  The  Pledge  is 
a  set  of  voluntary  commitments  that  facilitates 
cooperation  between  EOs  that  are  selling  through 
online  channels  and  MSAs.  E-commerce  actors  are 
encouraged to join the Pledge and help to ensure that 
fewer accidents occur due to unsafe products.

For national authorities
•	 Continue	 working	 on	 identified	 online	 market	
surveillance  -related  challenges.  Due  to  the 
increasing  share  of  e-commerce  and  changing 
consumer habits, challenges related to online market 
surveillance are here to stay for MSAs. MSAs should 
continue to help create better tools to monitor online 
markets and ensure safety of EU consumers.

•  Introduce  mystery  shopping.  MSAs  believe  that 
mystery shopping is an effective way to collect and 
test  samples  in  the  online  environment.  All  EU/EEA 
MSAs should consider introducing it, to help increase 
the effectiveness of their online market surveillance 
operations. 

•  Disseminate  CASP  2020  results.  MSAs  are 
encouraged  to  further  disseminate  the  results 
and  deliverables  of  the  CASP  2020  project.  MSAs 
are  particularly  encouraged  to  disseminate  the 
communications  material  that  was  developed  to 
maximise the impact and outreach of the project. 
•	 Benefit	 from	 the	 materials	 and	 insights	 made	

available via the CASP website3. 

Recommendations 

Based  on  the  discussions  during  the  meetings  of  the 
activity, a number of recommendations were formulated.

For consumers
•  Beware  of  the  risks  posed  by  products 
ordered  online.  Consumers should stay vigilant to 
products  sold  online.  If  the  product  seems  poorly 
manufactured or if the instructions are not available 
in  the  consumer’s  language  or  are  unclear,  do  not 
purchase the product. 

For EOs
•  Make  your  contact  details  available  to  MSAs. 
MSAs  might  find  it  difficult  to  contact  an  EO  that 
has sold a potentially dangerous product. Whenever 
EOs are selling through online channels, they should 
indicate their contact details in order to enable both 
EU/EEA MSAs and consumers to reach them in case 
there are safety issues with a product. 

•  Share  product  details.  Sometimes  not  enough 
details are shared, which makes it difficult for EU/EEA 
MSAs to identify whether the product was flagged via 
Safety  Gate.  EOs  should  share  as  many  details  as 
possible about their products to help MSAs to identify 
potentially dangerous ones1. 

•  Regularly  check  Safety  Gate.  In  order  to  make 
sure  that  only  safe  products  are  marketed  to  EU 
consumers, EOs should often check new notifications 
on Safety Gate and see if any of the products sold by 
them are deemed to be dangerous. This way EOs can 
make sure that they do not sell dangerous products 
to EU consumers. 

•  Cooperate  with  authorities  in  enforcement 
actions. In order to make sure that consumers only 
use  safe  products  and  do  not  get  injured,  EOs  are 
required to always cooperate with market surveillance 
enforcement  actions.  EOs  are  recommended  to 
use  the  Product  Safety  Business  Alert  Gateway  to 
proactively  notify  the  authorities  about  potential 
safety issues. 

1  A  non-exhaustive  list  of  details  might  include  the  following:  brand 
name,  model  number,  EAN  code,  reference  number,  batch  number,  list  of 
ingredients,  contact  details  of  manufacturer  or  European  representative, 
product pictures and warnings on the labelling.

2  https://ec.europa.eu/info/business-economy-euro/product-safety-and-

requirements/product-safety/product-safety-pledge_en

3  https://ec.europa.eu/safety-gate/#/screen/pages/casp

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CASP 2020 - Online market surveillancePART 1
1. Online Market Surveillance  
  activity overview

1.1 Introduction and objectives 

The  volume  of  e-commerce  is  continuously  increasing 
due to various technological advancements, the increase 
of  internet  penetration  and  the  Covid-19  pandemic 
(which  encourages  more  and  more  consumers  to 
purchase  non-food  products  from  online  channels4).  It 
also  seems  that  these  changing  consumer  habits  are 
here to stay, which will make online market surveillance 
critical in the future. 

Before the launch of the CASP 2020 project, DG JUST 
organised a priority setting exercise to gather input from 
MS  regarding  the  choice  of  products  and  activities  to 
be included in the coordinated activities. Among others, 
the OMS HA was identified as a priority. In addition, the 
CASP 2020 project also dedicated a number of activities 
to exclusively address online product safety, this HA was 
part of the CASP Online 2020 sub-project. 

Thanks  to  the  financial  and  operational  support  of 
the  EC  and  the  efforts  of  the  participating  MSAs,  this 

HA  focused  on  identifying  and  exploring  the  main 
challenges  MSAs  are  facing  when  performing  online 
market surveillance and co-created hands-on tools and 
solutions to overcome these. 

More specifically, the OMS HA was able to achieve the 
following objectives:
• 

identify,  prioritise  and  explore  the  most  important 
challenges faced by participating MSAs;

•  exchange  views  on  best  practices  related  to  these 

challenges;

•  co-create  tools  with  MSAs  to  help  overcome  their 

enforcement challenges;

•  develop  an  OMS  guidance  document  summarising 
the outcomes of the work carried out in the activity 
that can be used by all EU/EEA MSAs.

4  https://ec.europa.eu/eurostat/web/products-eurostat-news/-/DDN-

20200420-1

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CASP 2020 - Online market surveillance1.2 Overview of participating MSAs 

A total of 17 MSAs from 11 EU MS and 1 EEA MS participated in the OMS HA, as illustrated in Figure 1.

Figure 1 - Map of participating MSAs

IS

SE

FI

LV

DE

BE

LU

CZ

FR

BG

HR

MT

  Country
Belgium

Belgium

Belgium 

Bulgaria

Bulgaria

Croatia

MSA

Federal Public Service (FPS) Economy – Directorate-General for Quality and Safety

FPS Health, Food Chain Safety and Environment, Federal Environmental Inspectorate

FPS Health, Food Chain Safety and Environment – Directorate-General for Animals and Plants, 
Consumer Products Inspection Department

Commission for Consumer Protection

State Agency for Metrological and Technical Surveillance

State Inspectorate

Czech Republic

Czech Trade Inspection Authority

Finland

France

Germany

Germany

Germany

Iceland

Latvia

Finnish Safety and Chemicals Agency (Tukes)

Directorate-General for Consumer Competition and Fraud Enforcement (DGCCRF)

Bavarian Health and Food Safety Authority (LGL)

District Government of Düsseldorf 

Ministry of Environment, Climate Protection and the Energy Sector, Baden-Württemberg

The Consumer Agency – Neytendastofa

Consumer Rights Protection Centre

Luxembourg

ILNAS (Department of Market Surveillance)

Malta

Sweden

Malta Competition and Consumer Affairs Authority (MCCAA)

National Electrical Safety Board (Elsäkerhetsverket)

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CASP 2020 - Online market surveillance2. Summary of main activities  
  and outcomes

2.1 CASP 2020 OMS approach

The  OMS  HA  aimed  at  providing  MSAs  with  practical 
advice  and  hands-on  solutions  to  their  challenges. 
This task was performed in close cooperation with the 
participating  MSAs,  and  based  on  their  priorities  and 
needs. At the start of the activity, the MSAs decided to 
follow an approach focused on so-called ‘mini-projects’ : 
representatives from the national authorities were split 
into smaller groups to tackle selected challenges. 

After  identifying  the  most  important  challenges,  the 
mini-project  groups  explored  them  in  more  detail  and 
broke them down into basic topics. This was an important 
step to enable the design of solutions to specific issues. 
The  prioritisation  and  selection  of  the  challenges  took 
place during the activity’s kick-off meeting (KoM), while 
further  analysis  and  discussions  were  held  during  the 

first  intermediate  meeting.  Between  activity  meetings, 
MSAs–  worked  together  via  the  Wiki  platform  on 
the  specific  tools  that  offer  solutions  to  the  selected 
challenges, by sharing best practices, ideas and insights 
on  how  to  make  online  market  surveillance  more 
effective. The draft listing of tools was presented during 
the second intermediate meeting. 

The  mini  projects  resulted  in  four  tools  (now  part  of 
the  CASP  2020  OMS  guidance  document)  that  can  be 
used by all EU/EEA MSAs. They were refined according 
to MSAs’ feedback and were presented during the final 
activity meeting. 

The process map below shows the detailed methodology 
applied during the OMS activity.

Figure 2 – Overall approach applied in the RA activity

1. 
Data collection and 
analysis

Online survey, desk 
research to identify MSAs 
needs, challenges and 
existing best practices

2. 
Refinement	of	HA	
approach

Revision of the approach 
and listing all the 
challenges, based on 
feedback from MSAs and 
information collected via 
desk research

3. 
Kick-off	meeting

Joint decisions on the final 
activity scope by MSAs
Prioritisation of challenges 
and setting up  
mini-project teams

4. 
Co-creation and  
mini-project work – 
1st part

Breaking down challenges 
into their component parts
MSA teamwork via  
the Wiki platform

5.
 Intermediate 
meeting

Status update on the 
 mini-project work
Decisions tools and 
guidelines to offer 
solutions to challenges

10. 
Reporting

9. 
Final meeting

Wrap-up of the activity, 
incorporating final changes 
to guidance documents 
and producing the  
HA final report

Final guidance document 
is presented during the 
final meeting

8. 
Conclusions and 
recommendations

Guidance document 
including the tools 
prepared is shared via the 
Wiki platform in order to 
collect feedback 

7. 
Intermediate  
meeting

Status update on  
mini-project work
Feedback on the tools 
 and guidelines

6.
Co-creation and 
mini-project work – 
2nd part

Preparation of tools and 
guidelines with MSAs
Teamwork via the  
Wiki platform

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CASP 2020 - Online market surveillance2.2 Scoping of the activity

During  the  KoM,  MSAs  took  stock  of  all  the  online 
market surveillance related challenges in order to select 
the ones that were most urgent. These were used as the 
basis for the guidance document.  

Figure 3 below summarises the main challenges faced 
by MSAs.

Sampling  

Resources  

Jurisdiction  

Figure 3 - Online market surveillance related challenges faced by MSAs

With the increased volume of e-commerce, MSAs find it difficult to locate 
and collect samples from the online sources most likely to pose risks to 
consumers. 

MSAs often face budgetary constraints when developing or procuring di-
gital tools for identifying dangerous samples online and when conducting 
extra laboratory testing. 

Due to the cross-border nature of e-commerce, MSAs face enforcement is-
sues, for instance when products are purchased from an EO based outside 
the EU.

Guidelines, legislation  

The MSAs mentioned the need for more guidelines and new legislation to 
support them when conducting online inspections.

Identifications	of	Eos	 

It can be difficult for MSAs to identify and contact EOs selling via online 
platforms, as their contact details may be missing.

Reappearance of products 

If a dangerous product is banned from one online platform (for instance, 
based on a notification on Safety gate), it can easily reappear on the same 
platform or on another one.

Product	identification 

New products, platforms 

It can be difficult to identify dangerous or counterfeit products online as 
EOs often don’t share enough information about products (such as batch 
or model number).

It is difficult to decide if novel products sold online, like circular economy 
products, or products based on the internet of things, pose dangers to 
consumers or not. Moreover, new platforms like social networks have also 
become an integral part of the e-commerce ecosystem as they facilitate 
the online selling and buying of consumer products.

Collaboration

The MSAs stated that it is sometimes difficult to cooperate with online 
platforms.

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CASP 2020 - Online market surveillance 
 
 
 
 
 
 
 
2.3 Selection of key challenges

During  the  KoM,  MSAs  agreed  that  the  following 
challenges needed immediate attention: 
•  sampling (including mystery shopping)
• 
•  new platforms
•  re-appearance of products.

identification of EOs

Sampling
One  of  the  key  issues  in  online  market  surveillance 
is  selecting  the  products  most  likely  to  pose  risks 
to  consumers  for  inspection.  MSAs  face  four  main 
challenges in this area:

•  Tracking dangerous products online. The volume 
of  e-commerce  has  increased  significantly,  which 
makes  finding  and  tracking  dangerous  products 
online  difficult  for  authorities.  In  addition,  MSAs’ 
resources and tools often do not reflect this market 
change.

•  Mystery shopping. Mystery shopping is an effective 
way to collect samples from online sources enabling 
MSAs  to  conceal  their  identities  from  EOs.  In  some 
MS,  collecting  samples  from  online  sources  and 
conducting  online  mystery  shopping  are  not  yet 
standard practices, mainly due to national legislation, 
restrictive  internal  rules  or  a  lack  of  tools  (e.g. 
payment cards).

•  Golden  samples5.  EOs  selling  products  online  can 
easily identify MSAs based on their digital footprint. 
As a result, they may send golden samples to MSAs 
or they can constrain market surveillance activities in 
other ways.

•  Receiving  identical  specimens  of  the  same 
sample.  It  cannot  be  guaranteed  that  EOs  are 
sending  identical  specimens  of  the  same  sample 
(when MSAs require more specimens for testing6).

Identification	of	EOs
Another major challenge is to identify third-party sellers7 
selling  through  various  online  platforms.  Often,  the 
vendor information is not correct or it is impossible to 
identify who is selling a consumer product. 

•	 Identification	 of	 third-party	 sellers	 selling	
through EU and non-EU based online platforms. 
Online  platforms  in  this  context  are  defined  as 
platforms  that  connect  third-party  sellers  (EOs, 
manufacturers, retailers) and consumers. Third-party 
sellers’  details  are  often  missing,  making  it  difficult 
for MSAs to identify them. 

•	 Contacting	 identified	 third-party	 sellers.	 MSAs 
often  find  it  difficult  to  contact  third-party  sellers 
when they are non-EU based. It is also cumbersome 
to identify and contact profiles on social networks.

New platforms
New  platforms  in  this  context  are  defined  as  social 
networks  used  by  various  users  (natural  persons  and 
EOs or third-party sellers) to buy and sell products. New 
platform  users  (both  natural  persons  and  EOs)  may 
sell  new  and  second-hand  products.  Three  major  sub-
challenges were identified regarding new platforms.

•	 Identification	 of	 dangerous	 products	 on	 new	
platforms.  Third-party  sellers  often  do  not  share 
the necessary data about a product (model number, 
batch number, etc.), which makes it difficult for MSAs 
to identify dangerous products.

•	 Identification	 of	 third-party	 sellers	 on	 new	
platforms. It is often difficult to uncover the identity 
of third-party sellers as their details are not published. 
•  Removal  of  hazardous  products  from  new 
platforms. Sometimes MSAs find it difficult to pursue 
cooperation  with  new  platforms  when  dangerous 
products need to be removed from their sites. 

Re-appearance of products
Hazardous  products  that  have  already  been  removed 
can  easily  reappear  on  various  online  platforms.  Two 
sub-challenges were identified. 

•  Reappearance of already removed products on 
the same or another platform. Products that have 
already  been  taken  down  from  an  online  platform 
often reappear, and are sold by the same or different 
third-party  sellers  on  the  same  or  other  online 
platforms.

•	 Fulfilment	 centres8  and  traceability.  Fulfilment 
centres  play  a  central  role  in  e-commerce  as  they 
often  provide  shipping  and  packaging  services  for 
e-commerce  platforms.  These  actors  might  need  to 
play a bigger role in tracking dangerous products and 
notifying MSAs about them.

5  Golden samples are ‘premium units’ of very high quality compared to the 
rest of the products of the same type/batch that are submitted by an EO 
to a test house, external audit body or prospective customer. When golden 
samples are tested, MSAs may receive a false idea about the rest of the 
products in the batch. It is also worth mentioning that this term has no legal 
background, but has been used broadly in a market surveillance context. 
6  This  is  key,  as  in  many  MS,  products  belonging  to  different  batches  are 

legally deemed to be different products. 

7  Third-party sellers are independent sellers who offer a variety of new, used 

and refurbished items to consumers through online platforms.

8  Fulfilment  service  providers  or  centres  represent  a  new  business  model 
generated by e-commerce. These entities (natural or legal persons) provide 
at least two of the following services in the course of commercial activity: 
warehousing, packaging, addressing and dispatching – but do not own the 
products involved (https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=
CELEX:32019R1020&from=EN).

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CASP 2020 - Online market surveillance2.4 Identifying solutions

Following an in-depth exchange of views on the selected 
challenges,  MSAs  discussed  potential  solutions.  MSAs 
took stock of existing best practices and also held a joint 
brainstorming  exercise  in  order  to  explore  additional 
ideas. 

Four solutions were withheld: 
•  repository  for  digital 

tools  used  for  market 

surveillance;

•  best practice repository for mystery shopping;
•  protocol for cooperation with social networks;
•  data  exchange  between  MSAs  and  e-commerce 

platforms.

2.5 Co-development of solutions

Following  the  identification  of  the  challenges,  MSAs 
co-developed  solutions  using  the  online  Wiki  platform, 
where they were able to share comments and ideas in 
between project meetings and edit documents together.

Figure  4  summarises  the  content  of  the  tools  co-
developed by the MSAs.

Figure 4 - Tools co-developed by MSAs

Tool 1
digital tools 
repository

Mapping of available 
digital tools for market 
surveillance

Details of digital tools 
(description, strengths 
and attention points)

dvice and tips on how to 
use the tools

Tool 2
 mystery shopping 
best practices

Checklist of minimum 
requirements to 
introduce mystery 
shopping

Strengths and 
weaknesses

Collection of best 
practices (payment, 
delivery, social networks, 
etc.)

Tool 3
protocol for 
cooperation with 
social networks

General guidelines for 
cooperation
Areas for voluntary 
commitment from social 
networks
Guidelines on how to 
contact and negotiate 
with social networks

Tool 4
data exchange 
with e-commerce 
platforms

Roadmap and benefits 
of setting up a data 
exchange platform 
between MSAs and 
e-commerce platforms

Repository  of  digital  tools  used  to  identify 
dangerous products 
The  MSAs  mapped  all  the  existing  tools  and  methods 
available to increase the effectiveness of online market 
surveillance operations.

Technology
Websites, social media

Tools
1. 

Seasonal social media campaigns 

Table 1 - Inventory of existing OMS tools

2. 

3. 

Permanent central websites for consumers to report dangerous products

Social media influencers

Data-mining

4.  NettiDogi project

5. 

CASP 2019 data-mining proof of concept 

Web-crawling

6.  NordCrawl2 project 

Artificial intelligence (AI)

7. 

8. 

E-surveillance tool – a web crawler developed by DG JUST

SAFE web crawler tool 

The  tools  are  categorised  based  on  the  technology 
they use. A brief description of each tool is offered, the 
strengths and weaknesses of these tools are elaborated 
on and MSAs are provided with practical advice on how 
to implement them. 

This  repository  provides  guidance  for  MSAs  that  are 
looking to introduce digital tools. The overview could be 
updated  in  future  coordinated  activities  as  more  tools 
are developed and used by authorities. 

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CASP 2020 - Online market surveillanceData  exchange  between  MSAs  and  e-commerce 
platforms 
Data  exchange  between  MSAs  and  e-commerce 
platforms has an untapped potential in terms of making 
online  market  surveillance  more  effective.  This  tool 
explores making the exchange of certain relevant data 
automatic, and offers a roadmap for this. 

MSAs  found  that  using  existing  tools  and  further 
developing them would be the best option for exchanging 
data  with  e-commerce  platforms.  The  Business  Alert 
Gateway9  platform  seems  particularly  suited  to  allow 
for  the  exchange  of  data  and  information  between 
authorities and e-commerce platforms in a secure and 
transparent way. 

In addition, the tool describes the current state of data 
exchange  between  MSAs  and  e-commerce  platforms, 
sets out a vision of what a future data platform could 
look  like,  and  provides  a  roadmap  on  how  to  achieve 
this. 

Best practice repository on mystery shopping
Mystery shopping is an effective way to collect samples 
from online sources enabling MSAs not to reveal their 
identities to EOs. Many MSAs however are not applying 
mystery shopping due to restrictive regulations or a lack 
of resources. 

MSAs  co-developed  a  repository  that  aims  to  be  a 
reference  for  MSAs  that  have  not  yet  introduced 
mystery  shopping,  or  plan  on  improving  their  mystery 
shopping  capabilities.  The  tool  contains  the  following 
main elements: 

•  description of mystery shopping;
•  minimum requirements needed to introduce it;
• 
its strengths and weaknesses;
•  best practices used by MSAs.

The repository can be updated during future coordinated 
activities  based  on  the  experiences  of  participating 
MSAs. 

Protocol on cooperation with social networks
Social  networks  are  the  newest  members  of  the 
e-commerce  ecosystem  that  facilitate  the  sale  of 
consumer products online. The appearance of these new 
actors  poses  numerous  challenges  to  MSAs’  efforts  to 
ensure that only safe products are sold on the EU Single 
Market. In order to enable MSAs to lay down foundations 
for cooperation with these new e-commerce actors, the 
protocol  suggestions  aim  at  providing  a  starting  point 
for discussions between MSAs and social networks, and 
record MSAs’ requests to social networks. The protocol 
focuses on three main areas:

1.  General guidelines for cooperation
2.  Areas for voluntary commitment from social networks
3.  Contacting and negotiating with social networks.

5  https://webgate.ec.europa.eu/gpsd/

12

CASP 2020 - Online market surveillance3. Conclusions and recommendations 

3.1 General conclusions 

Online  market  surveillance  has  a  strategic  importance 
to MSAs due to changing consumer habits and market 
trends.  As  more  and  more  products  are  sold  and 
purchased  via  online  channels,  MSAs  need  to  shift 
their focus to these channels and make online market 
surveillance  part  of  their  daily  market  surveillance 
routine.  The  OMS  activity  of  the  CASP  2020  project 
aimed  at  achieving  this  by  exchanging  views  on 
challenges, best practices and possible solutions. 

In the OMS activity, the MSAs successfully explored the 
most important challenges they face in detail and co-
created tools that offer hands-on advice and guidance 
to overcome them. The tools are embedded in the CASP 

2020 OMS guidance document, which can be used not 
only  by  project  participants,  but  by  all  EU/EEA  MSAs 
aiming  at  improving  their  online  market  surveillance 
operations. 

Future  coordinated  activities  could  continue  exploring 
further  online  market  surveillance-related  challenges 
and solutions and complement and update the guidance 
document prepared in this activity. 

13

CASP 2020 - Online market surveillance•  Join  the  Product  Safety  Pledge11.  The  Pledge 
is  a  set  of  voluntary  commitments  that  facilitates 
cooperation  between  EOs  that  are  selling  through 
online  channels  and  MSAs.  E-commerce  actors  are 
encouraged to join the Pledge and help to ensure that 
fewer accidents occur due to unsafe products.

For national authorities
•	 Continue	 working	 on	 identified	 online	 market	
surveillance  -related  challenges.  Due  to  the 
increasing  share  of  e-commerce  and  changing 
consumer habits, challenges related to online market 
surveillance are here to stay for MSAs. MSAs should 
continue to help create better tools to monitor online 
markets and ensure safety of EU consumers.

•  Introduce  mystery  shopping.  MSAs  believe  that 
mystery shopping is an effective way to collect and 
test  samples  in  the  online  environment.  All  EU/EEA 
MSAs should consider introducing it, to help increase 
the effectiveness of their online market surveillance 
operations. 

•  Disseminate  CASP  2020  results.  MSAs  are 
encouraged  to  further  disseminate  the  results 
and  deliverables  of  the  CASP  2020  project.  MSAs 
are  particularly  encouraged  to  disseminate  the 
communications  material  that  was  developed  to 
maximise the impact and outreach of the project. 
•	 Benefit	 from	 the	 materials	 and	 insights	 made	

available via the CASP website12

3.2 Recommendations 

Based  on  the  discussions  during  the  meetings  of  the 
activity, a number of recommendations were formulated.

For consumers
•  Beware  of  the  risks  posed  by  products 
ordered  online.  Consumers should stay vigilant to 
products  sold  online.  If  the  product  seems  poorly 
manufactured or if the instructions are not available 
in  the  consumer’s  language  or  are  unclear,  do  not 
purchase the product. 

For EOs
•  Make  your  contact  details  available  to  MSAs. 
MSAs  might  find  it  difficult  to  contact  an  EO  that 
has sold a potentially dangerous product. Whenever 
EOs are selling through online channels, they should 
indicate their contact details in order to enable both 
EU/EEA MSAs and consumers to reach them in case 
there are safety issues with a product. 

•  Share  product  details.  Sometimes  not  enough 
details are shared, which makes it difficult for EU/EEA 
MSAs to identify whether the product was flagged via 
Safety  Gate.  EOs  should  share  as  many  details  as 
possible about their products to help MSAs to identify 
potentially dangerous ones10. 

•  Regularly  check  Safety  Gate.  In  order  to  make 
sure  that  only  safe  products  are  marketed  to  EU 
consumers, EOs should often check new notifications 
on Safety Gate and see if any of the products sold by 
them are deemed to be dangerous. This way EOs can 
make sure that they do not sell dangerous products 
to EU consumers. 

•  Cooperate  with  authorities  in  enforcement 
actions. In order to make sure that consumers only 
use  safe  products  and  do  not  get  injured,  EOs  are 
required to always cooperate with market surveillance 
enforcement  actions.  EOs  are  recommended  to 
use  the  Product  Safety  Business  Alert  Gateway  to 
proactively  notify  the  authorities  about  potential 
safety issues. 

10 A  non-exhaustive  list  of  details  might  include  the  following:  brand 
name,  model  number,  EAN  code,  reference  number,  batch  number,  list  of 
ingredients,  contact  details  of  manufacturer  or  European  representative, 
product pictures and warnings on the labelling.

11 https://ec.europa.eu/info/business-economy-euro/product-safety-and-

requirements/product-safety/product-safety-pledge_en

12 https://ec.europa.eu/safety-gate/#/screen/pages/casp

14

CASP 2020 - Online market surveillance3.3 Lessons learnt 

•  Co-creation and interactive exercises. During the 
activity,  tasks  were  performed  in  close  cooperation 
with the participating MSAs, based on their priorities 
and tapping into their collective knowledge and expe-
rience.  The  MSAs’  active  participation  in  developing 
solutions  and  deliverables  ultimately  increased  the 
quality of the activity outcomes and created a sense 
of ownership of the solutions found in the activity. 
•  Online  project  communication  and  team  work. 
The  Contractor  used  the  Wiki  platform  extensively 
as  a  project  communication  tool,  which  enabled  all 
participating  MSAs  to  quickly  find  and  approve  pro-
ject documents, exchange views with each other and 
receive  answers  to  their  project-related  questions 
almost instantly. In addition, the MSAs used this on-
line platform to work on project documents together, 
which proved to be an effective way to collect their 
input and feedback. 

•  Providing  hands-on  advice  and  ready-to-use 
tools.  In  addition  to  discussions  and  exchanges  of 
views,  MSAs  are  looking  for  hands-on  practical  ad-
vice on how to overcome their challenges related to 

online market surveillance and also for concrete tools 
that they can deploy to increase the effectiveness of 
their online market surveillance operations. The CASP 
2020  OMS  guidance  document  contains  advice  on 
important online market surveillance topics and the 
EC  web  crawler  tool,  and  is  available  to  all  EU/EEA 
MSAs. It may, therefore, provide a cornerstone for au-
thorities’ online market surveillance strategies.

•  Fully  digital  CASP  project.  Due  to  the  Covid-19 
crisis, the CASP 2020 project was the first one that 
had to be fully organised via digital means. Using di-
gital  project  communication  tools  allowed  MSAs  to 
contribute. Due to videoconferencing solutions, more 
representatives per MSA could get involved in project 
meetings and there was no risk of having fewer ex-
changes of views on important online product safety 
issues. 

15

CASP 2020 - Online market surveillancePART 2
1. What is CASP?

The  Coordinated  Activities  on  the  Safety  of  Products 
(CASP)  projects  are  aimed  at  ensuring  a  safe  Single 
Market  by  providing  national  market  surveillance 
authorities  with  the  necessary  tools  to  jointly  test 
products  found  in  the  Single  Market,  determine  their 
risks  and  draw  common  positions  and  procedures, 
through PSAs or Product Specific Activities.

Besides, the second objective of the CASP projects is to 
establish a meaningful exchange of ideas and of best 
practices for developing common approaches, guidelines 
and practical tools for common issues regarding market 
surveillance  on  product  safety,  by  means  of  HAs  or 
Horizontal Activities. 

HAs  aim  to  increase  the  consistency  of  practices  and 
approaches across the national authorities from Member 
States  and  EEA/EFTA  countries  in  charge  of  market 
surveillance. Specific activities undertaken within these 
coordinated  activities  aim  to  explore  existing  market 
trends  and  new  market  surveillance  challenges  linked 
to it; collect and discuss best practices and explore and 
develop ideas for new common approaches. 

The CASP 2020 project entails six Horizontal Activities, 
which  were  identified  through  a  consultation  launched 
by  DG  JUST  in  2019  to  explore  MSAs’  interests  and 
priorities:

1.  Risk assessment;
2.  Cooperation with customs;
3.  Recall effectiveness;
4.  Feasibility and modalities 

of an EU injury and accident database;

With  the  rise  of  e-commerce,  MSAs  expressed  their 
interest  to  focus  more  on  the  challenges  of  online 
product safety and market surveillance. Therefore, the 
CASP  Online  2020  sub-project  includes  coordinated 
activities addressing specifically issues related to online 
product safety in the EU and EEA. Two HAs are included 
in the CASP Online 2020 sub-project:

5.  Online market surveillance;
6.  Information campaign(s) for economic operators/

consumers.

1.1 Roles and responsibilities 

EISMEA
European Innovation Council and SMEs 

Executive Agency  
(successor Agency of CHAFEA)

DG JUST
Directorate-General for Justice  
and Consumers

>  Responsible for the implementation for 

>  Oversees the planning and execution of 

all coordinated actions falling under CASP 
2020

>  Monitors and approves all the contractual 

deliverables

the CASP initiatives

>  Ensures the operational leadership, 

management and successful 
implementation of the CASP projects
>  Supports the participating MSAs by 
providing guidance and stimulating 
interactions

Contractor
EY/Pracsis

Technical expert
One expert per HA

>  Coordinates the implementation and 

logistical organisation of the activities of 
the project

>  Provides technical advice and facilitates 

decision-making

>   Responsible for reporting, communication 
and dissemination of the outcome of the 
CASP 2020

>  Provides technical inputs throughout the 
project and offers guidance to the MSAs

>  Engages the project participants to 
identify useful knowledge and best 
practices

>  Shares findings and insights and 
facilitates knowledge exchange

16

 
1.2 Timeline of the project 

All the HAs follow the same approach in terms of methodology and timeline. 

Contractual 
Kick-off

Closing event

Kick-off 
meetings

1st Intermediate 
meetings

2nd Intermediate 
meetings

Final  
meetings

Inception 

Fieldwork

Reporting

Communication

Jan.

Feb. Mar.

Apr. May

June

July

Aug.

Sep.

Oct.

Nov.

Dec.

Jan.

Feb. Mar.

Apr. May

June

July

2020

2021

17

2. Overview of the HA approach

The  visual  below  depicts  the  general  approach  taken  in  the  HAs  following  the  contractual  KoM.  Crucial  to  the 
HA  approach  is  to  ensure  continuous  communication  between  participants  throughout  the  activity.  While  the 
different meetings are important milestones in each HA, communication between the meetings is ensured through  
a dedicated wiki platform that encourages continuous exchanges and collaboration.

1.
Data collection 
& analysis

Data is collected via 
survey, interviews and 
desk research.

The outcome is analysed 
to identify needs, gaps 
and challenges and to 
draw first conclusions.

2. 
Finetuning 
objectives and 
work plan

Elaboration on the 
approach and different 
options for the further 
roll-out of the project 
are shared together with 
the findings of the initial 
research and interviews 
on the wiki-platform.

3.
Kick-off	meeting

During the KoM a 
discussion is organised 
with MSAs on the best 
way forward in order to 
capture the goals and 
deliverables  
of the HA.

Based on input received 
the HA approach is 
refined.

4.
Start	of	HA-specific
activities

Further research is 
conducted on the 
specific topics defined 
and agreed during the 
KoM.

Work documents 
are shared with the 
participants on the wiki 
platform.

5.
First  
intermediate  
meeting

The progress of the 
work is presented and 
followed by a discussion. 
Results are shared on 
the wiki platform.

10.
Reporting

Wrap-up of the activity 
by incorporating final 
changes to guidance 
documents and 
producing the HA final 
report.

9.
Conclusions &
recommendations

Work/guidance 
documents and 
knowledge sharing tools 
are disseminated.

The HA final meeting 
provides an occasion 
to present the final 
outcome of the activity 
and address lessons 
learned and possible 
insights for future 
related activities.

8.
Finalisation of 
HA-specific	
activities

Based on the input 
received during the 
second intermediate 
meeting, work/guidance 
documents are finalised 
and knowledge sharing 
tools produced.

7.
Second intermediate
meeting

Based on the 
research performed 
the team proposes 
draft conclusions/
recommendations.

Participants provide 
feedback on the analysis 
and results presented 
as well as give inputs 
for possible knowledge 
sharing deliverables to 
be developed.

6.
Follow-up research
and progress
of	HA-specific
activities

Based on the input 
received during the first 
intermediate meeting, 
in collaboration with the 
MSAs further research 
is conducted, existing 
methodologies are 
improved and/or tools 
are further developed.

Scooping of the HA activity

HA-specific activities

Knowledge sharing activities

18

 
3. Communication activities

The CASP 2020 communication activities have to meet 
the  ambitious  challenge  of  communicating  the  results 
of  CASP  to  the  widest  audience  possible  across  the 
whole of the EU and beyond.

To achieve this, a comprehensive communication toolkit 
has been produced in all EU languages, focusing most 
strongly on PSA but also covering HA. The communication 
toolkit  is  available  online  on  the  Safety  Gate  website 
(https://ec.europa.eu/safety-gate/#/screen/pages/casp).

A  general  CASP  2020  report  and  a  CASP  2020  Online 
report are also available in all official EU languages. In 
addition, individual reports for each of  the activities in 
CASP 2020 are available in English, French and German. 
They are published on a dedicated CASP website under 
the Safety Gate umbrella website (https://ec.europa.eu/
safety-gate/#/screen/pages/casp) 

The  CASP  2020  Closing  Event  marks  the  end 
of  CASP  2020  and  triggers  the  launch  of  all 
in  the 
communication  material  produced 
project, the official publication of its results and 
the  activation  of  the  communication  toolkit 
across the EU.

19
19

EUROPEAN COMMISSION 
Directorate-General for Justice and Consumers 
Directorate Consumers 
Unit E.4 Product Safety and Rapid Alert System 
Email: JUST-RAPEX@ec.europa.eu

The European Commission is not liable for any consequence stemming from the reuse of this publication. 

© European Union, 2021. 
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changes are indicated.

For any use or reproduction of elements that are not owned by the European Union, permission may need to be sought directly from the 
respective rightholders. 

Information about the European Union in all the official languages of the EU is available on the Europa website at:
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Luxembourg: Publications Office of the European Union, 2021
PDF 

ISBN 978-92-76-32482-9   doi:10.2838/786712   DS-02-21-380-EN-N

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CASP 2020 - Online market surveillance