COMMISSION STAFF WORKING DOCUMENT EVALUATION Ex-Post Evaluation Consumer Programme 2014-2020
Date: 2026-01-15
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, 15.1.2026  SWD(2026) 10 final  COMMISSION STAFF WORKING DOCUMENT  EVALUATION  Ex-Post Evaluation Consumer Programme 2014-2020     {SWD(2026) 16 final}  
 
 
Commission Staff Working Document  

Ex-Post Evaluation Consumer Programme 2014-2020 

Contents 

1. 

INTRODUCTION ..................................................................................................... 1 

PURPOSE AND SCOPE OF THE EVALUATION.......................................................... 1 

2.  WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? ........... 3 

2.1 

2.2 

Policy context .................................................................................................... 3 

Description of the intervention and its objectives .............................................. 3 

2.3 Baseline and points of comparison ............................................................................ 5 

3.  HOW HAS THE SITUATION EVOLVED OVER THE EVALUATION PERIOD?
 ................................................................................................................................... 8 

3.1 Programme management ........................................................................................... 8 

3.2 Programme implementation ...................................................................................... 8 

4.  EVALUATION FINDINGS (ANALYTICAL PART) ........................................... 10 

TO  WHAT  EXTENT  WAS  THE  CONSUMER  PROGRAMME  SUCCESSFUL  AND 
WHY? ...................................................................................................................... 10 

4.1 Effectiveness ........................................................................................................... 10 

4.2 Efficiency ................................................................................................................ 26 

4.3 Coherence ................................................................................................................ 32 

4.4 How did the EU intervention make a difference and to whom? ............................. 39 

4.5 Is the intervention still relevant? ............................................................................. 42 

4.6 Further evaluation criteria ....................................................................................... 45 

5.  WHAT ARE THE CONCLUSIONS AND LESSONS LEARNED? ..................... 47 

5.1 Conclusions ............................................................................................................. 47 

5.2 Lessons learned ....................................................................................................... 50 

 
 
 
 
 
 
 
Glossary 

Term or acronym 

Meaning or definition 

ADR   

BEUC  

Alternative Dispute Resolution   

Bureau Européen des Unions de Consommateurs (European 
Consumer Organisation)  

CASP  

Coordinated Activities on the Safety of Products  

CHAFEA  

Consumers, Health, Agriculture, and Food Executive Agency  

CPAG 
CPN 
CPC  

CSN  

ECC  

Consumer Policy Advisory Group 
Consumer Policy Network 
Consumer Protection Cooperation  

Consumer Safety Network  

European Consumer Centre  

ECCRS  

European Consumer Complaints Registration System  

ECC-NET  

European Consumer Centres Network  

EESC 
EISMEA  

European Economic and Social Committee 
Executive Agency for Small and Medium-sized Enterprises  

EFTA 
EU  

GPSR  

ICPEN 
ICSMS 

IPSW 
KPI 
MS  

ODR  

European Free Trade Area 
European Union  

General Product Safety Regulation  

International Consumer Protection and Enforcement Network 
Information and Communication System for Market 
Surveillance 
International Product Safety Week 
Key Performance Indicator 
Member States  

Online Dispute Resolution  

OECD  

Organisation for Economic Co-operation and Development  

RAPEX / 
SafetyGate  

SafetyGate (formerly RAPEX): the EU rapid alert system for 
dangerous non-food products 

RSB 
SANCO  

SCCS  

SME  

Regulatory Scrutiny Board 
The Directorate-General for Health and Food Safety 

Scientific Committee on Consumer Safety  

Small and Medium-sized Enterprises  

 
 
 
1. 

INTRODUCTION 

PURPOSE AND SCOPE OF THE EVALUATION 

The purpose of this ex-post evaluation is to assess the outputs and outcomes achieved by the 
Consumer Programme 2014-20201 (hereinafter ‘Programme’), and the progress made towards 
the set objectives and its longer impact.  It focuses on the five evaluation criteria: effectiveness, 
efficiency,  relevance,  coherence,  and  the  EU  added  value  of  the  actions  funded.  Where 
applicable,  further  evaluation  criteria  were  applied:  utility,  complementarity,  equity, 
coordination, sustainability, and acceptability. 

It covers the period between 2014 and 2020, while building up on the findings, conclusions, 
and recommendations of the mid-term evaluation2. The mid-term evaluation covered the period 
between 2014 and 2017. It considers the implementation of the Programme in all EU countries, 
as well as in Norway and Iceland3. The evaluation exercise provides the necessary space for 
reflection  on  whether  the  Programme  had  been  flexible  to  respond  to  the  needs  of  its 
stakeholders, 
i.e.  consumer  organisations,  Consumer  Protection  Cooperation  (CPC) 
authorities,  European  Consumers  Centres  (ECC)  who  are  its  direct  beneficiaries,  and 
consumers who benefit from a better implemented and enforced consumer law. It identifies the 
main problems in its implementation and lessons learned. 

This retrospective evaluation meets the legal obligation set out in Article 34 of the Financial 
Regulation  (EU)  No 2018/10464.  The  Financial  Regulation  requires  an  evaluation  of  all 
programmes and activities that entail significant overall spending. While it does not define the 
level of the ‘significant spending’, the Better Regulation guidelines set an indicative threshold 
at least at EUR 5 million. The Programme was a continuation of the Consumer Programme 
2007-2013. It is closed now, while most of its activities continue to be funded under the Single 
Market Programme 2021-2027, albeit with some necessary adaptations5. To the extent possible 
the  evaluation  findings  will  feed  into  the  design  of  the  Multi-annual  Financial  Framework 
2028-2034. 

The  evaluation  applied  a  mixed-method  approach,  including  desk  reviews  of  literature, 
programme documentation, and a sample of grants and procurement files. Stakeholder input 
was  gathered  via  a  call  for  evidence,  an  online  survey  of  beneficiaries  (n  =  57),  targeted 

1  Regulation  (EU)  No 254/2014  of  the  European  Parliament  and  of  the  Council  of  26 February  2014  on  a 

multiannual consumer programme for the years 2014-20 and repealing Decision No 1926/2006/EC 

2  Report  from  the  Commission  to  the  European  Parliament,  the  Council,  the  European  Economic  and  Social 
Committee  and  the  Committee  of  the  Regions.  COM(2019)  490  final,  and  Commission  Staff  Working 
Document. SWD(2019) 382 final.  

3  According  to  Article  7  of  the  Programme  Regulation,  participation  in  the  Programme  shall  be  open  to  the 
countries of the European Free Trade Association participating in the European Economic Area, i.e. Norway, 
Iceland and Liechtenstein.  

4  Regulation  (EU)  No  254/2014  of  the  European  Parliament  and  of  the  Council  of  26  February  2014  on  a 

multiannual consumer programme for the years 2014-20 

5 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.  2015/2012  on  European  Standardisation,  and  financial 
contributions for the development of integrated European master’s degree courses in consumer issues. This 
Programme also took into account new priorities under the  Juncker Commission, including new focus on 
sustainable consumption and circular economy.  

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interviews, and five focus groups covering each Programme objective and one cross-cutting 
theme. The evaluation was supported by an external 6￼ and drew limited additional7.￼ Further 
methodological information is detailed in Annex II and Annex III. The structure of this report 
follows  the  five  evaluation  criteria  and  answers  the  evaluation  questions  per  Programme’s 
specific objective.   

The evaluation faced several methodological and data-related challenges, which were mitigated 
to the extent possible through triangulation and additional data collection. These limitations 
include: 

•  Data governance issues: Administrative changes during the Programme period led to 
incomplete  or  inconsistent  programme  management  data,  particularly  in  project 
tracking. 

•  Data accessibility and quality concerns: Funding and performance data, especially for 
procurement contracts, were manually recorded, often lacking standardisation, which 
affected reliability and comparability across actions. 

•  Stakeholder participation deficits: The overall response rate to the consultation tools 
was low. The online survey had only 57 responses, mainly from beneficiaries, which 
limits the generalisability of the findings. 

•  Methodological  limitations  in  indicator  design:  The  Programme  relied  heavily  on 
output-based  indicators  as  set  in  Annex  II  of  the  Regulation.  These  were  not 
systematically complemented by outcome or impact indicators, limiting the capacity to 
assess behavioural or systemic effects. 

Despite  this  multi-source  approach,  the  evaluation  encountered  major  data  limitations. 
Baselines for several outcome and impact-level indicators were missing or poorly defined at 
the outset of the Programme. For example, there was no shared baseline for consumer detriment 
beyond the one-off Consumer Detriment Study, no standardised data on whether businesses 
changed their compliance behaviour because of Programme-funded actions. While awareness 
and reach of campaigns were tracked, behavioural follow-up was rare, and longitudinal data to 
assess sustained effects were absent. Business-side data were also lacking, except for proxy 
indicators from CPC sweeps or RAPEX reactions. Inconsistencies in Member State reporting, 
especially within the CPC system, further limited the ability to assess cross-country effects. 
The  ODR  platform  itself  lacked  integrated  monitoring  of  user  satisfaction,  case  quality,  or 
reasons for complaint attrition, making it difficult to assess outcome quality. 

Mitigation  included  use  of  external  Scoreboard  data,  case  studies,  and  a  theory-of-change 
approach to assess causal links. Triangulation of qualitative and quantitative data supported the 
analysis,  although  the  lack  of  baseline  and  counterfactual  data  prevented  econometric 

6 The supporting study is available here:  
7 The evaluation assessed the views of civil society in selected Member States on the Programme’s effectiveness, 
relevance, and added value. It found that many organisations were unaware of the Programme or its broader 
objectives,  though  some  achievements,  such  as  RAPEX/Safety  Gate,  the  CPC  Network,  and  support  to 
policymaking, were recognised. The Programme was seen as flexible and responsive. Future programmes 
should ensure early involvement of civil society in their design. European Economic and Social Committee 
(EESC).  (2024).  Final  evaluation  of 
the  Consumer  Programme  (2014–2020).  INT/1053-EESC-
2024.https://www.eesc.europa.eu/en/our-work/opinions-information-reports/information-reports/final-
evaluation-consumer-programme-2014-2020  

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assessment. Scoreboards were used to contextualise findings, while stakeholder feedback was 
interpreted cautiously due to selection and recall bias. These constraints informed the careful 
framing of conclusions and lessons learned.  

2.  WHAT WAS THE EXPECTED OUTCOME OF 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.  Besides  the 
possibility to adopt legislative proposals in the context of completion of the internal market, 
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. The 
Commission outlined its strategic vision for EU consumer policy in the European Consumer 
Agenda8. To support the European Consumer Agenda and to cope with the challenges outlined 
in it, the Commission adopted a multi-annual Consumer Programme for the years 2014-2020. 
The  Programme  contained  targeted  policies  that  contributed  to  the  2030  Agenda  for 
Sustainable  Development9,  concretely  to  its  Goal  12  on  Sustainable  Consumption  and 
Production and Goal 3 on Ensuring Healthy Lives.  

2.2 Description of the intervention and its objectives 

Key challenges that the Programme was meant to address were identified in its 2011 impact 
assessment10: 
1. Product safety: Uneven enforcement across Member States and the lack of a pan-European 
framework compromised the safety of the Single Market. Global supply chains increased risks, 
while the absence of EU-level coordination reduced the value of co-financing. 
2.  Consumer  information  and  education:  Inadequate  data  on  consumer  behaviour,  weak 
capacity of consumer organisations (especially  in newer Member States), and lack of clear, 
comparable  information  hindered  consumer  decision-making,  particularly  in  cross-border 
contexts. EU tools were not adapted to digital developments.  
3.  Consumer  rights  and  redress:  Consumer  protection  remained  weak  in  cross-border 
situations,  with  low  confidence  in  online  shopping  and  limited  awareness  of  redress 
mechanisms.  There was  also  a need to  better integrate  consumer interests into EU policies, 
including digitalisation, sustainability, and social inclusion. 
4. Enforcement: the Consumer Protection Cooperation (CPC) Network was underutilised, with 
untapped  potential  for  coordination.  Moreover,  the  European  Consumer  Centres  Network 
(ECC-Net) lacked visibility, and needed strengthening to more effectively support cross-border 
complain resolution.  

The Programme’s intervention logic (see Figure 1) illustrates how its objectives, resources, 
and outputs are expected to generate results, based on key assumptions for success. It responds 
to a context of weak market monitoring, under-resourced consumer organisations, and limited 

8 COM(2012) 225 final 
9 https://sdgs.un.org/2030agenda 
10 COM(2011) 1320 final 

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consumer  awareness,  factors  that  contribute  to  higher  consumer  detriment  from  unsafe 
products and non-compliant business practices. 

To  address  these  challenges,  the  Programme  aimed  to  ensure  a  high  level  of  consumer 
protection, empower consumers, and place them at the centre of the internal market, in line 
with the Europe 2020 strategy (Article 2 of the Programme Regulation). It sought to protect 
consumers’  health,  safety,  and  economic  interests,  promote  their  rights  to  information  and 
education,  and  support  the  integration  of  consumer  interests  into  other  policy  areas.  The 
Programme complemented and supported Member State policies and was structured around 
four  specific  objectives  and  11  action  types  (Article  4  and  Annex  I),  further  detailed  in  40 
activities  (see  Table  1).  Funded  actions  addressed  digitalisation,  information  complexity, 
sustainability, and diverse consumer vulnerabilities. 

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Table 1:  Objectives and eligible actions under the Consumer Programme 2014-2020 

Objectives 

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. 

Actions 

(1) scientific advice and risk analysis relevant to consumer health and safety regarding 
non-food products and services including support for the tasks of the independent 
scientific committees established by Commission Decision 2008/721/EC 

(2) coordination of market surveillance and enforcement actions on product safety 
with regard to Directive 2001/95/EC of the European Parliament and of the Council 
and actions to improve consumer services safety; 

(3) maintenance and further development of databases on cosmetics 

(4) building and improving access to the evidence base for policy-making in areas 
affecting consumers, for designing smart and targeted regulations and for detecting 
any market malfunctioning or changes in consumers’ needs, providing a basis for the 
development of consumer policy, for the identification of the areas most problematic 
for consumers and for the integration of consumer interests into other Union policies; 

(5) support through financing of Union-level consumer organisations and through 
capacity building for consumer organisations at Union, national and regional level, 
increasing transparency and stepping up exchanges of best practices and expertise; 

(6) enhancing the transparency of consumer markets and consumer information, 
ensuring consumers have comparable, reliable and easily accessible data, including for 
cross-border cases, to help them compare not only prices, but also quality and 
sustainability of goods and services; 

(7) enhancing consumer education as a life-long process, with a particular focus on 
vulnerable consumers; 

(8) preparation by the Commission of consumer protection legislation and other 
regulatory initiatives, monitoring the transposition by Member States and the 
subsequent evaluation of its impact, and the promotion of co-regulatory and self-
regulatory initiatives and monitoring the real impact of those initiatives on consumer 
markets; 

(9) facilitating access to dispute resolution mechanisms for consumers, in particular to 
alternative dispute resolution (ADR) schemes, including through a Union-wide online 
system and the networking of national ADR entities, paying specific attention to 
adequate measures for vulnerable consumers’ needs and rights; monitoring of the 
functioning and the effectiveness of dispute resolution mechanisms for consumers, 
including through the development and maintenance of relevant IT tools, and the 
exchange of current best practices and experience in the Member States; 

Objective IV - Enforcement: 
to support enforcement of 
consumer rights by 
strengthening cooperation 
between national enforcement 
bodies and by supporting 
consumers with advice.    

(10) coordination of surveillance and enforcement actions with regard to Regulation 
(EC) No 2006/2004 of the European Parliament and of the Council 

(11) financial contributions for joint actions with public or non-profit bodies 
constituting Union networks which provide information and assistance to consumers 
to help them exercise their rights and obtain access to appropriate dispute resolution, 
including out of court online resolution schemes (the European Consumer Centres 
Network [ECC-NET]) 

Source: REGULATION (EU) No 254/2014 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 26 February 2014 on a multiannual 
consumer programme for the years 2014-20 and repealing Decision No 1926/2006/EC.  

The  intervention  logic  of  the  Programme  provided  the  conceptual  foundation  for  this 
evaluation.  It  mapped  how  the  Programme  was  intended  to  achieve  its  general  objective, 
ensuring  a  high  level  of  consumer  protection  and  enhancing  consumer  confidence  in  the 

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internal market, through a sequence of actions organised under four specific objectives. This 
logic linked inputs, activities, outputs, outcomes, and long-term impacts, while also making 
key assumptions about how and why the intervention would work. The evaluation used this 
logic to systematically test whether causal links materialised and whether these assumptions 
held in practice. 

The intervention logic followed a theory-of-change structure: 

→  If the Programme funded cross-border cooperation and enforcement tools (e.g. CPC, 

ECC-Net), 

→  Then Member States would better enforce consumer protection rules, 

→  Which leads to greater consumer confidence and protection in the Single Market. 

Objective I: Funding for coordinated actions on product safety → better market surveillance 
→ fewer unsafe products. 

through 

Each  of  the  Programme’s  specific  objectives  followed  a  distinct  causal  pathway.  Under 
Objective I, the Programme funded activities such as scientific risk assessments, data-sharing 
the  Safety 
mechanisms,  and  market  surveillance  coordination,  particularly 
Gate/RAPEX  system.  The  underlying  assumption  was  that  more  timely  and  accurate 
information would enable national authorities to respond more effectively to unsafe products, 
while at the same time providing for cost saving, as testing did not have to be repeated across 
Member States. This was explored in the evaluation using Safety Gate/RAPEX data, which 
indicated that the proportion of reactions to alerts increased substantially, from 39% at baseline 
to over 70% by the end of the Programme. The Coordinated Actions for the Safety of Products 
(CASP) provided complementary evidence through coordinated testing, joint risk assessments, 
and market surveillance campaigns. Results of all activites can be found in Safety Gate/RAPEX 
and  ICSMS,  but  most  importantly  trust  and  methods  of  cooperation  between  MSAs  was 
fostered,  and  common  risk  assessment  methodologies  were  developed.  Complex  or  novel 
products  that  provided  a  challenge  to  MSAs  were  also  addressed  in  CASP.  Despite  those 
actions being a step towards improved product safety across the EU, enforcement responses 
varied considerably across Member States, reflecting differences in administrative capacity and 
prioritisation. The available evidence suggests that the causal link between alerts and consumer 
protection was stronger where authorities acted promptly, and weaker in Member States with 
limited resources or follow-up mechanisms. 

Objective II: Consumer education tools → increased knowledge of rights → more confident 
and empowered consumers. 

Objective II addressed consumer awareness, education, and support for civil society actors such 
as  consumer  organisations.  Activities  included  Europe-wide  awareness  campaigns,  market 
studies, and capacity-building support to national and EU-level organisations. The underlying 
assumption  was  that  better-informed  consumers  would  make  more  confident  and  rational 
decisions, thereby reducing the incidence of detriment and improving trust in the market. The 
evaluation  tested  this  logic  through  Consumer  Conditions  Scoreboard  data  and  campaign 
metrics. Within this logic, campaigns like #YourEUright aimed to reach large audiences across 
the EU to increase knowledge of rights, while capacity-building support to organisations such 
as  BEUC  sought  to  strengthen  their  ability  to  advocate  for  consumers  and  engage  in 

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policymaking at both EU and national levels. The causal pathway therefore linked large-scale 
information provision and enhanced organisational capacity to intermediate outcomes such as 
higher consumer awareness, stronger representation, and ultimately more informed consumer 
choices and improved market trust. 

Objective  III:  Development  and  promotion  of  ADR/ODR  mechanisms  →  better  access  to 
redress → reduced need for court procedures. 

Under Objective III, the Programme aimed to improve access to redress through actions such 
as the development of the Online Dispute Resolution (ODR) platform and support for national 
Alternative Dispute Resolution (ADR) schemes. The assumption was that increasing access to 
easy,  low-cost  dispute  mechanisms  would  reduce  unresolved  complaints  and  increase 
consumer satisfaction. This assumption was tested using ODR usage statistics and ADR uptake 
data. Within this logic, the ODR platform was intended to offer consumers and traders a simple, 
multilingual  entry  point  for  resolving  cross-border  disputes  online,  while  support  to  ADR 
schemes aimed to expand their availability, improve quality standards, and ensure consistent 
coverage across the EU. The causal pathway linked the availability and accessibility of these 
mechanisms to higher resolution rates, greater consumer confidence in seeking redress,  and 
ultimately improved market trust. 

Objective IV: Support for ECC-Net and CPC sweeps → improved enforcement and consumer 
support → higher trust in cross-border commerce. 

Objective IV focused on enforcement, supporting joint actions between national authorities, 
coordination through the CPC network, and the work of the ECCs. The Programme assumed 
that better cooperation tools and training would lead to faster, more consistent enforcement of 
consumer law across borders. Within this logic, CPC cooperation mechanisms, shared IT tools, 
and targeted training were intended to strengthen cross-border case handling, facilitate timely 
information exchange, and enable coordinated market surveillance actions. Support to ECCs 
was designed to enhance assistance to consumers in cross-border cases, feeding intelligence 
back into enforcement networks. The causal pathway linked these measures to intermediate 
outcomes  such  as  more  efficient  resolution  of  enforcement  requests,  greater  consistency  of 
enforcement actions across Member States, and ultimately higher levels of consumer protection 
in the internal market. 

The  evaluation  tested  these  assumptions  and  causal  links  using  a  mix  of  quantitative  and 
qualitative methods. Indicators from Annex II of the Regulation were used to assess outputs, 
including the number of RAPEX alerts, ECC contacts, ODR complaints, and grants awarded. 
To evaluate outcomes and impacts, the assessment relied on the Consumer Scoreboard, ECC 
and  CPC  network  data,  and  key  studies  such  as  the  2017  research  on  measuring  consumer 
detriment.  Focus  groups,  interviews,  and  project  reporting  also  provided  insights  into 
behavioural effects and enforcement practices, helping to validate or challenge the assumptions 
embedded in the logic model. 

Beyond  its  internal  logic,  the  Programme’s  outcomes  were  shaped  by  external  factors.  The 
COVID-19  pandemic  increased  consumer  vulnerability  and  accelerated  digitalisation, 
highlighting  the  need  for  flexible,  digital-first  tools  while  disrupting  some  enforcement 
activities. Rapid growth in e-commerce introduced new challenges not foreseen at design stage. 
Regional  disparities  in  consumer  awareness  and  institutional  capacity  also  influenced 
implementation success. Additionally, interaction with other EU initiatives (e.g. LIFE, Rights 

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and Equality, Consumer Agenda) created both synergies and attribution challenges. To assess 
the  effectiveness  and  coherence  of  the  Programme,  the  intervention  logic  was  not  only 
reconstructed  but  also  used  systematically  throughout  the  evaluation  as  an  analytical 
framework. 

Figure 1: Intervention logic of the 2014-2020 Consumer Programme 

CHALLENGES 

risks from unsafe 
products in the 
Single Market 

lack of targeted 
regulation to address 
market failures, limited 
knowledge of consumer 
rights among consumers 
and traders,  

Limited consumer 
empowerment, 
especially in cross-
border and digital 
contexts, , underuse 
of redress 
mechanisms 
(including 
ADR/ODR),  

inconsistent 
enforcement of 
consumer law, 
enforcement 
coordination among 
national authorities 
often slow 

GENERAL 
OBJECTIVES 

to empower consumers and raise the level of consumer protection in the EU, thereby increasing 
consumer confidence in the single market.  

SPECIFIC 
OBJECTIVES 

improve product 
safety in the single 
market (through 
effective market 
surveillance across 
the EU) 

enhance consumer 
information, education, 
develop the evidence 
base for consumer 
policy, and support 
consumer organisations  

Strengthen consumer 
rights and improve 
access to redress 
mechanisms   

Improve cooperation 
and exchange of 
information and 
enforcement requests 
between national 
authorities 

INPUTS 

EU Programme 
funding 

Beneficiaries co-
financing 

EC management and administrative resources 

ACTIVITIES 

Safety 
Gate/RAPEX 
notifications, 
information sharing, 
events and 
meetings, 
exchanges of 
officials, common 
testing, 
development of risk 
assessment 
methodologies, 
development of 
guidelines and 
handbooks for 
MSAs 

Awareness raising 
campaigns, consumer 
education resources, 
support to EU-level 
consumer organisations, 
capacity-building for 
consumer organisations, 
consumer market studies, 
scoreboards and surveys 

facilitating access to 
dispute resolution 
mechanisms for 
consumers, 
development of 
relevant IT tools 
(ODR, ADRs), 
exchange of best 
practices, behavioural 
research 

E-enforcement 
training academy, 
exchanges of CPC 
officials, joint sweeps, 
IT tools, ECC-Net 
activities 

CAUSAL 
LINKS and 
ASSUMPTIONS 

Activities generate outputs by creating tools, knowledge, and coordination mechanisms. These 
outputs enable changes in consumer and authority behaviour (outcomes). Cumulative behavioural 
changes result in stronger market outcomes and long-term consumer protection gains (impacts). 
Each step assumes uptake and use by target groups (consumers, businesses, enforcers) and 
functional coordination across Member States. 

National authorities will act upon alerts and risk assessments. Information campaigns will lead to 
knowledge and behaviour change. Redress tools will be used if accessible and visible. Enforcement 
cooperation will improve outcomes (dependent on national commitment). Evidence and research 
will feed into policymaking. 

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OUTPUTS 

OUTCOMES 

surveillance and 
enforcement actions 
on product safety, 
scientific advice and 
risk analysis 
relevant to 
consumer health for 
non-food products 

consumer organisations 
with increased capacity 
to support consumers, 
improved consumer 
awareness, better 
information about 
consumer markets and 
problematic areas, 
improved evidence base 
for smart policy-making 

Improved removal 
of unsafe products 
from the market and 
stronger cross-
border enforcement 
coordination.    

consumers and traders 
better informed of 
consumer rights, 
increased trust in 
organisations protecting 
consumers rights 

facilitated access to 
low-cost redress 
(ADR/ODR), 
improved knowledge 
of consumer 
behaviour  

enhanced capacity of 
enforcement 
authorities, trained 
officials, coordinated 
surveillance and 
enforcement actions, 
consumer rights 
enforced 

Greater consumer 
access to redress, 
especially in cross-
border and digital 
disputes  

Stronger and more 
coordinated 
enforcement of 
consumer protection 
rules 

IMPACTS 

Increased consumer confidence in the single market, including online and cross-border shopping. 
Higher level of traders’ compliance with EU consumer law. More consistent protection and 
enforcement across all Member States.  

DATA 
SOURCES and 
DATA GAPS 

Annex II indicators (e.g. RAPEX reactions, CPC request handling times, ODR complaints 
submitted); Consumer Scoreboard; CPC and ECC-Net databases; 2017 study on consumer 
detriment; Interviews and focus groups, data from a sample of funded projects and procurement 
actions.  

No shared baseline for consumer detriment. No longitudinal data for sustained behaviour change. 
Incomplete Member State reporting. Lack of outcome metrics in ADR/ODR. No direct business 
compliance data. 

EXTERNAL 
FACTORS 

•  Delays  and  inconsistencies  in  the  transposition  and  implementation  of  relevant  EU 

legislation (e.g. ADR Directive) 

•  Variable Member State capacity, resources, and prioritisation of consumer protection 
• 
Limited stakeholder engagement and awareness, especially among traders 
• 
Insufficient or fragmented data, complicating performance tracking and impact assessment 
•  COVID-19  pandemic,  which  temporarily  disrupted  implementation  but  also  accelerated 

digital adaptation 
Technological  and  market  developments,  such  as  the  rise  of  e-commerce,  creating  new 
consumer protection challenges 
Functional limitations of central tools (e.g. ODR platform, CPC IT systems) 

• 

• 

Table  2  below  provides  a  list  of  key  indicators  used  in  the  evaluation,  each  mapped  to  the 
corresponding level of the intervention logic (output, outcome, or impact).  

2.3 Baseline and points of comparison 

This  evaluation  compares  situation  at  the  end  of  the  previous  Consumer  Programme  2007-
201311 with the situation after the implementation of the Consumer Programme 2014-2020, as 
well  as  the  expected  results  set  out  in  the  Programme’s  Impact  Assessment  with  the  actual 
outcomes achieved. Baseline and comparison data were drawn from a range of sources: the 

11 Following the mid-term evaluation of the Programme, the baseline values for the indicators were defined to be 
the  average  over  the  three  years  preceding  the  Programme,  i.e.  the  average  over  2011-2013.  Where  the 
available data did not allow to calculate an average over the years 2011 to 2013, other years were used as the 
baseline, generally the most recent period for which data were available. 

5 

 
 
 
 
 
Impact assessment of the Consumer Programme 2014-202012; the Mid-term evaluation of the 
Consumer Programme 2014-202013; the Ex-post evaluation of the Consumer Programme 2007-
201314;  the  Explanatory  memorandum  of  the  Proposal  for  a  Regulation  on  a  Consumer 
Programme 2014-2020; the Mid-term evaluation of the 2007-2013 Programme of Community 
Action15; and operational  data operational data (e.g. Safety Gate/RAPEX reports, ECC data 
and ODR statistics, Consumer Scoreboards, Eurobarometer surveys, CPC records).  

The  evaluation  compared  expected  outcomes  with  results  using  key  quantitative  indicators 
from  Article  3  of  the  Programme  Regulation  (see  Table  2).  For  outputs  (e.g.  alerts,  ECC 
contacts),  2010–2013  served  as  a  de  facto  baseline;  for  outcomes  (e.g.  consumer  trust  or 
awareness),  historical  Scoreboard  data  (2011–2013)  were  used.  No  formal  baselines  were 
available  for  impact-level  objectives  like  reduced  consumer  detriment,  so  proxy  indicators 
were  cautiously  applied.  The  2017  Consumer  Detriment  Study  provided  a  benchmark  for 
financial,  time-related,  and  psychological  harm  in  some  instances,  though  not  formally 
integrated  into  Programme  monitoring.  Its  lack  of  repeat  application  limited  trend  analysis. 
External  developments  such  as  digitalisation,  cross-border  e-commerce,  and  COVID-19 
reshaped  the  consumer  landscape,  complicating  direct  attribution  of  outcomes  to  the 
Programme. A contribution-based approach was adopted, using triangulated evidence to assess 
plausible causal links without overstatement. 

Table 2: Key indicators under the Programme Regulation 

Objec
tive 

Indicator 

1 

1 

RAPEX 

% 
of 
notifications 
entailing at least one 
reaction 
(by  other 
Member States) 

Ratio  number  of 
reactions/number  of 
notifications (serious 
risks)16 

Baseline 
(annual 
average 
2011-2013) 

39% 

1.03 

Target 
(2020) 

Increase 
of  10%  or 
47.5% 

Increase 
of  15%  or 
1.23 

2020 end 
state 

Achievement 

Intervention 
logic level 

Annual 
average 
(2014-
2020) 

    50% 

72% 

1.87 

2.69 

    Target 
significantly 
achieved 

Outcome 

Target 
significantly 
achieved 

Outcome 

12   COM(2011) 1320 final, https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52011SC1320  
13   Report from the Commission to the European Parliament, the Council, the European Economic and Social 
Committee  and  the  Committee  of  the  Regions.  COM(2019)  490  final,  and  Commission  Staff  Working 
Document. SWD(2019) 382 final. 

14   European Commission, Consumer Policy: Ex-post and Mid-term Evaluations Final Report (2018) 
15   Commission  staff  working  document,  Evaluation  of  the  Consumer  Policy  Strategy  and  Programme  of 
Community  Action:  Ex-post  evaluation  of  the  2004-2007  Programme  of  Community  Action;  Mid-term 
evaluation of the 2007-2013 Consumer Policy Strategy; Mid-term evaluation of the 2007-2013 Programme 
of Community Action, SEC(2011) 414 final 

16   A notification can trigger several reactions from authorities of other Member States.   

6 

 
 
 
 
 
 
 
 
Objec
tive 

Indicator 

Target 
(2020) 

Baseline 
(annual 
average 
2011-2013) 

Annual 
average 
(2014-
2020) 

2020 end 
state 

Achievement 

Intervention 
logic level 

2  Number 

complaint 
submitting 
complaints 
ECCRS 

of 
bodies 

to 

the 

38 

70 

2  Number of countries 

7 

20 

submitting 
complaints 
ECCRS 

to 

the 

*2014-
2017 
66 

*2014-
2017 
20 

*2017 
77 

Target 
achieved 

Output 

*2017 
24 

Target 
achieved 

Output 

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

ODR 

2010:  17  500 
complaints 
by 
received 
ECCs 
related 
to e-commerce 
transactions 

100.000  

147.000 

147.000 

Target 
exceeded 

Output 

2010: 9% 

75% 

17% 

24% 

Significant 
decline 

Outcome 

3  %  of 

and 

those  cases 
the 
dealt  with  by 
not 
ECCs 
resolved 
directly 
with  traders  which 
subsequently 
were 
to 
referred 
alternative 
dispute 
resolution (ADR) 
Source: Annual ECC 
Report 

action 
to 

3  % of consumers who 
in 
took 
response 
a 
problem encountered 
in the past 12 months 
Source:  Consumer 
scoreboard 

4  Number  of  requests 
exchange 
to 
information  between 
CPC authorities 
Source: 
CPC 
Network  Database 
(CPCS) 

4  Number  of  requests 
enforcement 
between 

for 
measures 
CPC authorities 
CPC 
Source: 
Network  Database 
(CPCS) 

4  Number  of  alerts 
the  CPC 

within 
Network 
Source: 
CPC 
Network  Database 
(CPCS) 

2010: 83% 

90% 

72% 

67.4

Decline 

Impact 

% 

80 

139 

58 

Increase 
of  30%  or 
168 

Increase 
of  40%  or 
185 

Increase 
of  30%  or 
82 

73 

25 

Significant 
decline 

Output 

144 

113 

Decline 

Output 

53 

78 

average 

Output 

On 
stable 

7 

 
 
Objec
tive 

Indicator 

4  %  of  enforcement 
handled 
requests 
within  12  months 
within 
the  CPC 
Network 
Source: 
CPC 
Network  Database 
(CPCS) 

4  %  of 

information 
requests 
handled 
within  3  months 
the  CPC 
within 
Network 
Source: 
CPC 
Network  Database 
(CPCS) 

4  Number  of  contacts 
with 
consumers 
handled by the ECCs 
Source: ECC reports 

4  Number  of  visits  to 
the  websites  of  the 
ECCs 
Source: 
Evaluation Report 

ECC-Net 

Target 
(2020) 

Baseline 
(annual 
average 
2011-2013) 

47% 

60% 

Annual 
average 
(2014-
2020) 

33% 

2020 end 
state 

Achievement 

Intervention 
logic level 

28% 
*2019 

Significant 
decline 

Outcome 

33%17 

50% 

31% 

36% 

average 

Outcome 

On 
stable 

74 182 

Increase 
of  50%  or 
106 500 

114 355 

167 833 

Target 
exceeded 

Output 

2 335 000 

2 839 000 

5 186 002 

6  702  905 
(2019) 

Target 
exceeded 

Output 

Source: Data compiled from RAPEX/Safety Gate annual reports, ECCRS administrative data (2014–2017), ODR platform statistics, ECC 
annual reports, CPCS enforcement data, and Consumer Conditions Scoreboards. Indicators calculated using annual averages or latest available 
data (2014–2020), with 2011–2013 used as baselines where applicable.  

Overall, the Programme exceeded targets in product safety alerts (Objective I) and ODR use 
(Objective III), and made strong progress in cross-border protection (Objective II). However, 
enforcement  cooperation  under  the  CPC  Network  (Objective  IV)  declined  in  volume  and 
timeliness, largely due to national resource constraints and procedural complexity. Despite this, 
most consumer-facing outputs outperformed the 2011–2013 baseline. 

3.  HOW HAS THE SITUATION EVOLVED OVER THE EVALUATION PERIOD? 

3.1 Programme management  

The  Programme  was  managed  by  DG  Justice  and  Consumers  and  implemented  by  the 
Consumer,  Health,  Agriculture  and  Food  Executive  Agency  (CHAFEA)  until  its  closure  in 
2021,  after  which  responsibilities  were  transferred  to  the  European  Innovation  Council  and 
SMEs Executive Agency (EISMEA). The transition affected the accessibility of data storage, 
and documentation, creating challenges for the evaluation.  

3.2 Programme implementation   

The  Commission  implemented  the  Programme  via  annual  work  programmes.  Funding  was 
provided  through  operating  grants,  action  grants  (including  joint  actions  between  Member 
States),  event  grants,  enforcement  grants,  and  procurement  contracts  for  studies,  IT  tools, 
training, and awareness campaigns. Co-financing rates ranged from 50% to 95% (Article 8 of 

17 Average 2007-2010; no data available for 2011-2013.  

8 

 
 
 
the Programme Regulation). Funding was awarded through competitive procedures, including 
calls for proposals, tenders, reimbursements, and indemnities. 

3.3 Budget overview 

The Programme was allocated a budget  of  EUR 188.8 million, with  an additional  EUR 5.6 
million from EFTA countries (Norway and Iceland), bringing the total to EUR 194.4 million. 
Of  this,  EUR  175.5  million  was  for  operational  commitments  and  EUR  18.9  million  for 
administrative  and  support  costs,  64%  of  which  went  to  executive  agencies.  Annual 
commitments  were  stable,  with  a  notable  increase  in  2019.  Payments  lagged  behind 
commitments,  with  no  disbursement  in  2014.  From  2015  to  2024,  EUR  169.9  million  was 
spent, yielding an absorption rate of 87.4%, higher than comparable programmes like LIFE 
(64.1%) and Rights, Equality and Citizenship (84.2%).  

Grants amounted to EUR 62.2 million, supporting 270 projects across 30 countries and 130 
beneficiaries.  Most  funding  went  to  Objective  IV  (69%),  followed  by  Objective  II  (21%), 
Objective I (8%), and Objective III (2%). Only seven projects were cross-border. Funding was 
concentrated in Belgium, Germany, and the Netherlands, which received 47% of total grant 
funds. Grants typically covered half of project costs. Procurement totaled EUR 107.7 million, 
financing  573  contracts  with  116  entities.  While  many  contracts  were  under  EUR  100,000, 
large projects like RAPEX/Safety Gate, CASP, the ODR platform, and consumer campaigns 
absorbed nearly half the budget. Procurement levels were steady (EUR 11 million/year) except 
in 2019, when funding nearly doubled due to a shift from grants to procurement in key areas.  

The total cost of the Programme is estimated at EUR 230 million. This includes EUR 194.4 
million from the EU budget, and an estimated EUR 41.5 million in co-financing provided by 
grant beneficiaries. The actual co-financing rates varied between 50% and 95% depending on 
the type of action and beneficiary. Therefore, a weighted average co-financing rate of 60% was 
applied to estimate the overall contribution from stakeholders. By objective, Objective II and 
IV received the largest shares of funding (32% and 35%, respectively). Under Objective II, 
Action 4 (evidence base) and Action 5 (support to consumer organisations) received the most 
funding, while Action 7 (consumer education) saw notable growth. Under Objective I, Action 
2  (market  surveillance  coordination)  accounted  for  86%  of  funding,  with  a  58%  increase 
between 2018–2019 following a strategic shift to procurement. Table 3 and Annex V provide 
further detail on funded projects by year and activity. 

Table 3: Overview of main actions and activities funded under the Programme 
Objective 
I – Product 
Safety 

Type 
Procurement  CASP Joint 

Funding (in EUR)  Key Outputs/Results 
15 million 

Activities 

Actions 

Action 
Action 2 – 
Market 
surveillance 
Action 2 – 
RAPEX/Safety 
Gate platform 
Action 5 – 
Support to 
Consumer Orgs 

I – Product 
Safety 

II – Consumer 
Education 

14 product categories, 26 
joint actions, 25 
participating MS 
New functionalities, 
business access, 
improved MS integration 
Annual advocacy, policy 
contributions, 
stakeholder coordination 

Procurement  Maintenance 
and upgrades 

Part of 15 million  

Grant 

BEUC  

3.4 million 

9 

 
 
 
 
>500 teacher accounts; 
limited sustainability and 
uptake 
Train-the-trainer in 8 
MS; low participation 
outside BEUC network 
Fed into CCD and DSA 
initiatives 

Launched in 2016; 147k 
complaints; low % 
routed to ADR 
Recommendations for 
minimum quality 
standards 
Improved data exchange 
and enforcement 
coordination 
Annual checks of online 
terms, dark patterns, 
price transparency 
900,000+ consumer 
contacts; >60% 
resolution rate 

II – Consumer 
Education 

II – Consumer 
Education 

II – Consumer 
Education 

III – Redress 

III – Redress 

Action 7 – 
Consumer 
Classroom 
Action 7 – 
Consumer 
Champion 
Action 6 – 
Behavioural 
studies 
Action 9 – ODR 
Platform 

Action 9 – ADR 
quality study 

Procurement  Educational 

1.1 million 

Grant 

platform 

Training 
programme 

0.9 million 

Procurement  Consumer 

0.5 million 

Credit & Online 
Reviews 

Procurement  ODR Platform 

0.8 million 

development 

Procurement  Legal/regulatory 

0.2 million 

study 

IV – 
Enforcement 

Action 10 – 
CPC IT Tool 

Procurement  CPC 

2.5 million 

improvements 

Grant 

Grant 

Website/content 
enforcement 

Part of CPC 
envelope 

ECC consumer 
support 

44.5 million  

IV – 
Enforcement 

Action 10 – 
CPC Sweeps 

IV – 
Enforcement 

IV – 
Enforcement 

Action 11 – 
ECC-Net 
Operating 
Grants 
Action 11 – 
ECCNet2 IT 
system 

Procurement  Feasibility + 

implementation 

Included in ECC-
Net funding 

Improved case handling 
and MS integration 

Source: based on the Commission’s internal monitoring and project documentation. 

4.  EVALUATION FINDINGS (ANALYTICAL PART) 

To what extent was the Consumer Programme successful and why? 

4.1 Effectiveness 

This section assesses whether activities funded delivered the expected outputs and contributed 
to  outcomes  and  impacts  in  line  with  the  intervention  logic.  The  evaluation  found  that  the 
Programme has been broadly effective in achieving its objectives.   

Objective I: Product Safety  
Objective I aimed to ensure a high level of product safety across the EU   through activities 
funded under Actions 1 to 3: provision of scientific advice, coordination of market surveillance 
and  enforcement,  and  risk  analysis.  Over  80%  of  the  objective’s  operational  budget  was 
allocated to Action 2, especially via the Safety Gate/RAPEX system and CASP (Coordinated 
Activities on Safety of Products).  

The  mid-term  evaluation  found  that  the  funded  activities  were  largely  effective.  Safety 
Gate/RAPEX became a central pillar of EU market surveillance, enabling rapid cross-border 
communication and information sharing between national authorities. Between 2014 and 2020, 
over 14 000 alerts and 30 000 follow-up actions were recorded, demonstrating its expanding 
reach18.  However,  achievement  levels  were  influenced  by  limited  staffing  and  financial 
resources  in  national  market  surveillance  authorities.  Stakeholders  noted  the  continued 

18 Safety Gate Reports 2014-2020.  

10 

 
 
 
presence of unsafe products, especially due to e-commerce, cross-border trade, and the rising 
complexity of items like connected devices and wearables. These trends demanded more agile 
enforcement, straining existing capacities. Nonetheless, the Programme demonstrated strong 
effectiveness  through  sustained  investment  in  CASP  and  ongoing  development  of  Safety 
Gate/RAPEX, including new business reporting tools and better integration with national IT 
systems19.  The  Safety  Gate/RAPEX  enables  the  rapid  exchange  of  information  between 
national authorities on measures taken against products, thus facilitating coordinated actions 
across  the  single  market.  It  also  provides  accessible  information  to  the  wider  public  via  its 
online portal.20   

Table  2  above  presents  progress  under  Objective  I,  based  on  two  key  indicators  from  the 
Regulation. The percentage of Safety Gate/RAPEX notifications triggering follow-up actions 
rose steadily from 2014 to 2018. A dip to 51%)21 was due to a surge in COVID related alerts 
with limited traceability, but by 2020 the rate climbed to 72%, far exceeding the 47.5% target 
set.  The  reactions-per-notification  ratio  also  improved  from  1.28  in  2014  to  2.69  in  2020, 
its 
showing  stronger  cross-border  cooperation.  Safety  Gate/RAPEX  demonstrated 
effectiveness and agility, especially during the pandemic, for example, 25 million unsafe masks 
were  flagged  in  June  2020.  In  2019–2020,  alerts  covered  about  41.8  million  products, 
averaging  77,900  per  notification,  with  97%  classified  as  serious  risks22.  Most  notifications 
concern serious risk (97%), highlighting the system’s focus on preventing the most dangerous 
threats to consumer health and safety. Data quality also improved over the Programme period, 
with  fewer  notifications  missing  key  manufacturer  details  like  batch  numbers  or  barcodes. 
However, gaps remain regarding product identification (e.g. model type), pointing to a need 
for further improvements23. The steady volume of dangerous goods reported and followed up 
through Safety Gate/RAPEX indicates that coordinated action and rapid communication have 
helped reduce unsafe products in the EU market.  

Focus group participants confirmed Safety Gate/RAPEX’s critical role in consumer protection 
but identified areas for improvement. A key gap is the lack of linked accident or injury data, 
which limits the ability to fully assess consumer safety impacts. Participants also stressed the 
need  for  more  harmonised  risk  assessments  and  regular  training  for  national  authorities. 
Ongoing  efforts,  mainly  through  CASP,  are  addressing  these  challenges.  Limited  product 
traceability,  especially  in  complex  global  supply  chains,  remains  a  barrier  to  effective 
enforcement.  Participants  suggested  that  allowing  trusted  external  bodies  (e.g.  consumer 
organisations) to submit structured alerts could enhance responsiveness. Some also noted that 
they  rarely  receive  follow-up  from  authorities  after  submitting  product  concerns,  which 
undermines  feedback  loops  and  system  trust.  Improved  interoperability  between  Safety 
Gate/RAPEX and ICSMS allowed faster data sharing and reduced duplication; by 2020, over 
90% of national authorities used ICSMS to upload surveillance findings. 

19 CASP reports 2019-2020; Safety Gate/RAPEX annual reports.  
20 Every day, national authorities send alerts. Each alert contains information about the type of product detected 
as dangerous, a description of the risk and the measures taken by the economic operator or mandated by the 
authority. These alerts are followed-up by other authorities, who take their own measures if the same product 
is found in their national markets. If they indeed discover it, they must also share this information on Safety 
Gate.  

21 RAPEX annual report 2014 to 2020.  
22 Safety Gate/RAPEX annual reports 2019 and 2020.  
23 Evaluation final report GPSD, 2022.  

11 

 
 
 
Joint cooperation and enforcement actions and the Coordinated Activities on the Safety 
of  Products  (CASP)  significantly  enhanced  national-level  market  surveillance.  These 
initiatives  supported  implementation  of  the  General  Product  Safety  Directive  (Directive 
2001/95/EC) through coordinated testing, risk assessment, surveillance operations, awareness 
campaigns,  and  customs  cooperation.  In  CASP  2019  and  2020,  17  product  categories  were 
assessed. In 2019, 652 products were tested, with a 75% non-compliance rate, generating 170 
RAPEX  alerts.  In  2020,  775  products  were  tested  across  12  activities,  with  unsafe  or  non-
compliant  products  ranging  from  12%  to  over  80%,  depending  on  the  product  group. 
Specialised  labs  carried  out  risk  assessments  that  often  triggered  RAPEX  activity.24  25 
Stakeholders,  including  national  surveillance  authorities,  CSN  members,  and  EU  officials, 
stressed that joint  tools  like guidelines and handbooks improved coordination and capacity, 
especially for smaller Member States.  26 CASP also piloted innovative cooperation methods, 
such  as  mystery  shopping  in  e-commerce,  joint  communication  campaigns,  and  rapid  risk 
assessments during COVID-19. These activities strengthened technical capacity and promoted 
a more harmonised and proactive surveillance culture across the EU. 

The Scientific Committee on Consumer Safety (SCCS) provided essential risk assessments 
that shaped EU safety regulations. During the term 2016-202127, it adopted 66 final opinions, 
including  on  hair  dyes  (14),  cosmetic  ingredients  (30),  nanomaterial  in  cosmetics  (9),  and 
statements and other outputs (13). The important output documents of the SCCS are the ‘SCCS 
Notes of Guidance for the testing of the cosmetic ingredients and their safety evaluation’ (9th28, 
10th29  and  11th  revisions30),  as  well  as  a  memorandum  on  the  use  of  In  Silico  Methods  for 
Assessment  of  Chemical  Hazards.  These  opinions  have  had  major  impact  on  legislation  of 
cosmetic products, by providing the risk assessment on which the risk management decisions 
were taken.31 The 11th revision also aimed to make findings more accessible to non-experts, 
including regulators and businesses. Beyond cosmetics, the SCCS contributed to the EU-wide 
debate on nanomaterial safety, extending its impact to other regulatory areas. 

The Programme also promoted consumer safety through networking and awareness initiatives, 
including the CSN, its permanent Safety Gate/RAPEX subgroup, the International Product 

24 CASP 2019 Final Report 
25 CASP 2020 Final Report 
26 GPSD Evaluation 2020 
27 https://op.europa.eu/en/publication-detail/-/publication/0e5e6484-0073-11ee-87ec-01aa75ed71a1  
28https://ec.europa.eu/health/scientific_committees/consumer_safety/docs/sccs_o_190.pdf?utm 
29https://health.ec.europa.eu/document/download/8d49f487-909c-4498-af89-

1f769aaa628c_en?filename=sccs_o_224.pdf 

30https://health.ec.europa.eu/document/download/89af1a70-a2b1-44da-a868-

e7d80a8e736c_en?filename=sccs_o_250.pdf 

31 Numerous SCCS evaluations of cosmetic ingredients have been implemented as technical adaptations of the 
Annexes of the Cosmetic Regulations; for example: Commission Regulation (EU) 2016/1198 of 22 July 2016 
amending Annex V to Regulation (EC) No 1223/2009 of the European Parliament and of the Council on 
cosmetic products (MI), Commission Regulation (EU) 2017/237 of 10 February 2017 amending Annex III to 
Regulation (EC) No 1223/2009 of the European Parliament and of the Council on cosmetic products (hair 
and  eyelash  dyes),  Commission  Regulation  (EU)  2018/885  of  20  June  2018  amending  Annex  VI  to 
Regulation (EC) No 1223/2009 of the European Parliament and of the Council on cosmetic products (MBBT 
nano), Commission Regulation (EU) 2019/680 of 30 April 2019 amending Annex VI to Regulation (EC) No 
1223/2009 of the European Parliament and of the Council on cosmetic products (UV filter S86), Commission 
Regulation (EU) 2020/1682 of 12 November 2020 amending Annex III to Regulation (EC) No 1223/2009 of 
the European Parliament and of the Council on cosmetic products (HEMA).  

12 

 
 
 
Safety Week (IPSW), and the Product Safety Awards. Held biennially since 2006, IPSW 
brings global safety experts together to foster cooperation. The 2020 edition, held online due 
to  COVID-19,  drew  500+  participants  from  78  countries,  far  exceeding  its  target  of  120. 
Discussions  focused  on  pandemic-related  product  safety  challenges.  The  Product  Safety 
Award,  launched  in  2019  by  DG  JUST,  recognises  companies  exceeding  EU  safety 
requirements. In its first edition, eight businesses were honoured across gold, silver, and bronze 
categories32.   

International  cooperation  with  organisations  like  Health  Canada  and  more  recently  the 
OECD33, have expanded the Programme's global impact, however, it remained very limited so 
far.  The  OECD  Global  Recall  System  enabled  the  EU  to  share  information  on  dangerous 
products.  The  Safety  Gate/RAPEX  China  exchange  started  in  2006.  The  cooperation  with 
China  also  involved  the  SPEAC  (Safe  non-food  consumer  products  in  the  EU  and  China) 
initiative  that  helped  identify  Chinese-origin  unsafe  products.  Stakeholders,  including 
representatives from national market surveillance authorities, members of the Consumer Safety 
Network (CSN), and EU-level officials, expected results to grow as collaboration structures 
mature. 

The Programme also supported exchanges of safety enforcement officials through visits, joint 
investigations, and workshops. These increased from 19 in 2014 to 56 in 2017, despite resource 
constraints. However, due to budget cuts, only one exchange project (“CASP VisitUs”) was 
funded in 2019, with several planned visits cancelled due to COVID-19. Evaluations suggested 
such exchanges could be more effective if linked thematically to wider initiatives like CASP. 
Authorities  also  recommended  digital  formats  as  cost-effective  tools,  especially  for  smaller 
agencies.34 

In the Programme’s survey, stakeholders rated Objective I’s effectiveness at 4.2/5, echoing the 
mid-term evaluation’s “largely effective” finding. Reported benefits included stronger cross-
border cooperation, better access to product safety data, and reduced consumer risk. However, 
cooperation with third-country authorities was identified as a continuing weakness.The 2020 
study  on  the  implementation  of  the  General  Product  Safety  Directive  (GPSD)35  highlighted 
persistent  challenges  in  EU  product  safety  enforcement,  notably  uneven  implementation 
across Member States due to differences in administrative capacity and surveillance practices. 
The COVID-19 pandemic further strained systems, disrupting inspections and exposing gaps 
in rapid response. The study called for more staffing, better technical tools, and enhanced cross-
border  coordination  to  build  a  more  resilient  enforcement  framework.The  Product  Safety 
Pledge,  initiated  in  2018,  complements  the  General  Product  Safety  Directive  by  outlining 
commitments of online marketplaces that go beyond their legal obligations. For example, they 
committed to remove dangerous product listings flagged by authorities within  two working 
days. By the end of-2019, four major online platforms, Amazon, eBay, AliExpress, Rakuten 

32  Report 

first 
gate/#/screen/pages/SafetyAwardPreviousEditions  

edition  of 

from 

the 

the  Product  Safety  Award:  https://ec.europa.eu/safety-

33 The Programme did not finance the  cooperation with Health Canada and OECD, however, the international 

cooperation was enriched through the funded RAPEX/Safety Gate project.  

34 GPSD Final Evaluation Report (2022–2023), Volume I and Annex 4 (Capacity Building); CASP 2020 Final 

Report, Section 4.2: Recommendations and Lessons Learned. 

35 Civic (2020): Study for the preparation of an implementation report of the GPSD, Final Report Part 1, available 

athttps://commission.europa.eu/document/download/04a83d71-f7dc-4656-b0e0-
efac46b53bae_en?filename=final_report-gpsd-part1-main_report-final-corrected2.pdf   

13 

 
 
 
France, had signed the pledge. Self-reported data from 1 April 2019 to 31 September 201936, 
show that 96,42% of flagged listings were removed following a governmental notice within 
two days, and 93,56% of identified listings following the monitoring of public recall databases 
were also removed within the two days.  While the Pledge helped test commitments that later 
became legal obligations under the General Product Safety Regulation (GPSR), focus group 
participants (e.g. national authorities, ANEC, BEUC, DG JUST, EISMEA) noted its voluntary 
nature  and  limited  transparency  reduced  its  overall  effectiveness,  particularly  in  informing 
consumers who had already purchased flagged products have also integrated the use of Safety 
Gate/RAPEX and allow for discussions around risk assessment between market surveillance 
authorities  

The  evaluation  also  examined  wider  effects  beyond  formal  indicators,  such  as  consumer 
confidence  in  product  safety,  trust  in  enforcement,  and  retailer  perceptions.  Consumer 
Conditions survey data (see Table 4) show that the share of EU consumers who believe most 
non-food products are safe rose from a baseline of 68% to 72% in 2020, despite a slight dip in 
2018. This trend is consistent with mid-term evaluation findings and indicates broadly stable 
or improving consumer confidence over the Programme period. 

Table 4: Overview of progress compared to 2011-2013 baseline (indicators for potential 
wider effects – Objective I) 

Indicator  

Baseline 
(annual  average 
2011-13)  

End of evaluation period 
(2020  unless  otherwise 
stated)  

Progress made   

% of EU consumers who agree that essentially all non-food 
products  are  safe  or  that  a  small  number  of  non-food 
products are unsafe  

68%  

%  of  retailers  who  agree  that  public  authorities  actively 
monitor  and  ensure  compliance  with  product  safety 
legislation in their sector  

81%  

(EU 

72% 
2020) (2021)  

average, 

++   

(EU 

74% 
2018) (2019)  

average, 

-  

Key ++ = significant improvement made; + = improvement made; 0 = stable;  - = negative trend; - - = significant 
decline  

Source: Year-on-year differences indicated in the Consumer Conditions surveys (2015-2020 editions).  

The  rise  in  consumer  confidence  may  partly  reflect  the  cumulative  impact  of  Programme-
funded actions, particularly Safety Gate/RAPEX, CASP, and the CSN. Over 2,000 alerts were 
issued annually, with follow-up actions reaching 4,477 in 2019, showing the EU’s swift and 
visible response to product risks37. In contrast, retailer trust declined. The share of EU retailers 
who  believed  public  authorities  ensured  compliance  fell  from  81%  (2011–2013)  to  74%  in 
2018 (Consumer Conditions Survey). This likely reflects enforcement challenges linked to e-
commerce  growth  and  complex  supply  chains.  The  GPSD  Evaluation  echoed  this  concern, 
citing  uneven  Member  State  resources  and  difficulties  policing  online  and  imported  goods. 
While  the  Programme  supported  improvements,  these  efforts  may  not  have  fully  countered 
declining perceptions of oversight among retailers.  

36  European  Commission:  2nd  Progress  Report  on  the  implementation  of  the  Product  Safety  Pledge, 

https://commission.europa.eu/document/download/409c5a4e-593b-41ff-927b-
754fc8aaa795_en?filename=2nd_progress_report_product_safety_pledge.pdf  

37 Safety Gate Reports 2018-2020.  

14 

 
 
 
Objective  II:  Consumer  information  and  education,  evidence  base  and  support  to 
consumer organisations 
The  mid-term  evaluation  found  that,  by  the  end  of  2017,  the Programme  delivered  mixed 
results. It was effective in developing the evidence base, with Scoreboards and market studies 
influencing consumer policy at both EU and national levels. It also successfully supported EU-
level consumer organisations, notably BEUC. However, consumer information and education 
measures,  such  as  the  Consumer  Champion  training  and  Consumer  Classroom,  were  less 
effective. Although awareness campaigns met engagement targets, they had limited long-term 
impact on consumer awareness. Key challenges included limited resources, lack of curriculum 
integration, and the inability of training alone to overcome organisational capacity gaps. The 
evaluation  concluded  that  information  campaigns  had  mixed  results  in  contributing  to  the 
Programme’s objectives. Despite earlier challenges, more recent campaigns showed improved 
reach  and  engagement.  Fully  funded  by  the  Programme,  these  educational  efforts  aimed  to 
boost awareness  and confidence, particularly in  cross-border online shopping. According to 
interviews and literature, they helped inform consumers about their rights. The #YourEUright 
campaign,  targeting  18–35-year-olds,  used  social  media,  influencers,  and  interactive  events 
(e.g.  escape  rooms),  reaching  over  319  million  contacts  and  generating  94  million 
interactions38. Other specific campaigns included an information campaign to raise consumer 
awareness on their rights39, a campaign targeting young consumers between 18 and 35 years 
old about what rights they have when they take out a credit, and an awareness raising on energy 
efficiency  targeting  energy  poor  households40.  An  ‘ex-ante  evaluation  for  awareness  raising 
and promotion campaign for energy efficiency in households’ was conducted to guide decision-
making on the use of the Programme resources for communication campaigns. An evaluation 
of  the  campaign  on  consumer  credit  rights  among  young  consumers  concluded  that  the 
campaign’s objectives were relevant, given low financial literacy levels in Austria and Czechia, 
however, the age range was too broad for effective communication. The campaign had limited 
impact,  raised  only  low  awareness.  Focus  group  and  survey  results  showed  no  significant 
increase  in  knowledge.  Media  coverage  was  modest,  mostly  found  in  financial  sections 
unlikely  to  be  read  by  young  adults.41  While  the  campaigns'  targets  in  terms  of  hits  or 
impression  were  typically  achieved,  little  long-term  impact  on  consumer  awareness  was 
discernible. Although ECCs and CSN made considerable efforts to reach vulnerable consumers 
through  dedicated  campaigns  and  educational  materials,  evaluation  of  the  campaign 
suggested42 that more tailored communication strategies are needed to ensure these groups are 
adequately informed and protected, particularly in the digital marketplace. This finding aligns 
with  that  of  the  EESC,  according  to  whom  several  communication  initiatives  under  the 
Programme,  although  well-intentioned  and  broadly  disseminated,  lacked  precision  in  their 
targeting  and  sustainability  of  impact.  The  Committee  highlighted  that  without  long-term 

38 WPP Government & public sector practice, 2024, (Case study: empowering young EU citizens to confidently 

use their consumer rights). https://govtpracticewpp.com/case-study/youreuright/ 

39 https://ec.europa.eu/newsroom/just/items/30149/en  
40 An ‘ex-ante evaluation for awareness raising and promotion campaign for energy efficiency in households’, an 
internal  evaluation  report,  was  produced,  showcasing  good  practice  in  decision  making on  the  use  of  the 
Programme resources for communication campaigns.  

41 Draft Final Report, CCD campaign, September 2016, internal unpublished document.  
42 https://govtpracticewpp.com/case-study/youreuright 

15 

 
 
 
engagement strategies or culturally tailored messages, awareness  efforts risk  limited uptake 
and retention among harder-to-reach communities43. 

The European Consumer Complaints Registration System (ECCRS) aimed to harmonise 
complaint  reporting  and  support  cross-country  comparisons44.  Between  2014  and  2017,  the 
number of complaint bodies submitting data rose from 37 to 77, exceeding the target of 70 by 
2015.  Similarly,  country  participation  increased  from  13  to  24,  surpassing  the  target  of  20. 
Despite meeting these quantitative goals, the ECCRS was phased out in November 2018. A 
review  cited  concerns  over  IT  security,  data  protection,  and  the  complexity  and  limited 
usability  of  the  system.  These  issues  led  to  a  shift  toward  more  streamlined  data  collection 
methods. 

BEUC, the EU-level umbrella group for 44 consumer organisations in 31 countries, received 
EUR 11.95 million under Objective II, around 19.5% of the Programme’s total grant funding. 
Its core role was to coordinate national consumer organisations, provide information, training, 
and ensure effective EU-level advocacy. Evaluations found this support to be highly effective, 
with  stakeholders,  especially  national  consumer  organisations,  noting  that  without  BEUC’s 
coordination,  they  would  struggle  to  engage  meaningfully  at  EU  level.  The  2015–2018 
framework  partnership  tracked  BEUC’s  outputs  via  KPIs  (e.g.  website  visits,  downloads, 
training sessions), which were largely met or exceeded. However, BEUC acknowledged that 
these indicators did not fully capture its impact, such as its policy influence, media engagement, 
and  network  mobilisation.  Notable  contributions  included  coordination  on  EU  legislative 
proposals  (e.g.  collective  redress,  digital  services),  launch  of  the  Consumer  Champion 
platform,  and  cooperation  with  enforcement  networks.  Although  BEUC’s  press  releases 
averaged  23  per  year  (below  the  36  baseline),  output  peaked  at  42  in  2020,  reflecting  its 
response  during  COVID-19.  While  media  impact  was  not  systematically  tracked,  BEUC 
remained visible and respected in EU policy circles. Table 5 summarises the wider effects of 
consumer information and education under Objective II, using survey data from 2014–2020. 
The first indicator: consumer knowledge of EU rights, measures correct answers to questions 
on unsolicited goods, cooling-off periods, and guarantees. Performance rose from 9% in 2014 
to 49.2% in 2016, dipped to 45.5% in 2018, and remained below the 52% baseline. The average 
over 2014–2018 was 35%, weighed down by the low 2014 score. No data was available for 
2020. The second indicator, trust in NGOs to protect consumer rights, increased slightly from 
62% in 2014 to 64.6% in 2018, but remained well below the 74% baseline (2011–2013), despite 
peaking  at  72.2%  in  2016.45 These  trends  suggest  that,  despite  significant  investment  (e.g. 

43  European  Economic  and  Social  Committee  (EESC).  (2024).  Final  evaluation  of  the  Consumer  Programme 

(2014–2020). INT/1053-EESC-2024. 

44  The  data  relied  on  the  voluntary  cooperation  of  various  complaint-handling  bodies  across  Member  States, 
including  authorities,  consumer  associations,  ADR  bodies,  and  ECCs.  However,  it  excluded  complaints 
directed  at  traders  and  was  not  fully  representative,  as  data  contributions  varied  over  time  and  were  not 
submitted  by  all  relevant  entities.  The  system’s  operation  was  based  on  a  non-binding  recommendation, 
limiting consistency and completeness across countries. 2006-2018 consumer complaint data are available 
here:https://commission.europa.eu/strategy-and-policy/policies/consumers/consumer-protection-
policy/evidence-based-consumer-policy/consumer-complaints-statistics_en 

45 Note that there were changes in question wording and answer items in 2014 and 2016 and in 2020. In 2020 a 
question was added: if consumers knew  that a  contract cannot include a clause to raise the price  significantly 
without offering the possibility to cancel. This means the data published in 2023 cannot be directly compared with 
earlier data.   

16 

 
 
 
 
BEUC  coordination,  EU-wide  campaigns),  the  Programme's  information  and  education 
activities had limited long-term impact on consumer awareness and trust. The decline in NGO 
trust likely reflects broader societal mistrust, low digital visibility of consumer organisations, 
and the growing complexity of consumer markets. 

Table 5: Overview of progress (indicators for potential wider effects - Objective II)  

Indicator  

Baseline 
(annual 
average 
2011-13)  

Evaluation  period 
average 
(annual 
2014-2020)  

Final 
(2018)  

status 

Progress made   

proportion 

Average 
of 
correct  responses  to  three 
knowledge  questions  about 
EU consumer rights *,a  

52%  

Percentage  of  consumers 
who  agree  that  they  trust 
non-governmental 
consumer  organisations  to 
protect consumer rights  

74%  

35%   

(2014-2018a, 
average)  

66%   

(2014-2018c 
average)  

45.5%  
b 

- decrease from the baseline. Figure unknown 
for 2020.  

64.6%  

- decrease from the baseline. Figure unknown 
for 2020.  

Key ++ = significant improvement made; + = improvement made; 0=stable; - = negative trend  
Notes: Averages calculated on basis of the available annual data.   
a The three knowledge questions relate to receiving unsolicited products, cooling off period, and faulty product guarantee.  
b The figure of 9% in 2014 skews the annual average for the years 2014, 2016 and 2018.  
c This proportion of consumers in 2020 was not published in 2023.  
(*) Averages calculated on basis of the available annual data.  
Source: Compilation based on year-on-year differences indicated in the Commission’s 2014 - 2020 surveys of 
consumers’ attitudes toward cross-border trade and consumer protection.   

Despite efforts to improve consumer awareness, achieving tangible educational outcomes—
particularly among young people, remained difficult. Consumer Classroom, launched in 2013 
as a multilingual EU platform for secondary school teachers (students aged 12–18), provided 
resources on consumer rights, sustainable consumption, and financial literacy. While it offered 
a rich library and collaborative tools, uptake was limited. Focus group participants attributed 
this to low school interest, largely because consumer education is not integrated into national 
curricula.  This  highlights  the  ongoing  challenge  of  embedding  consumer  topics  in  formal 
education systems across Member States.  

Consumer  Champion,  launched  in  2014,  aimed  to  build  the  capacity  of  consumer 
organisations  through  training,  networking,  and  resource  sharing.  Managed  by  BEUC  until 
2018, the programme aligned with Digital Single Market goals and featured an online platform 
as  a  collaborative  hub.  However,  it  struggled  with  user  engagement,  especially  with  its  e-
learning modules. Stakeholders noted the need for more localised content tailored to national 
contexts and sectors like telecoms, digital services, and e-commerce. The impact of the 2019 
transition  from  BEUC  to  the  Commission  could  not  be  assessed,  due  to  the  absence  of 
consistent performance data before and after the shift. Consumer PRO is a train-the-trainer 
programme implemented by BEUC from 2019 to July 2021, focused on equipping consumer 
professionals with comprehensive knowledge of consumer law to facilitate peer training. The 
programme successfully conducted  28 planned and 14 additional national  training sessions, 
reaching  over  735  professionals  and  six  European  workshops  attended  by  178  participants. 
Satisfaction rates were notably high, ranging from 90% to 100%. Follow-up surveys showed 

17 

 
 
that most participants were able to transfer the knowledge (80% for national trainings, 73% for 
workshops)  and  apply  the  resources  (77%  and  76%  respectively).  The  majority  reported  a 
positive impact on themselves or their organisations (94% and 93% respectively).46 Consumer 
Law Ready, launched in 2016 by the Commission in partnership with BEUC, Eurochambres, 
and SMEUnited, aimed to improve SMEs’ understanding of EU and  national consumer law 
and  thereby  fostering  consumer  trust.  Initially  coordinated  by  BEUC,  the  project  later 
transitioned to Eurochambres. Since 2017, it has built a network of 24 national lead trainers 
and around 2,500 local trainers across 24 Member States, training around 3,000 SMEs. The 
programme covered topics like pre-contractual information requirements, right of withdrawal, 
guarantees, unfair contract terms and unfair commercial practices. It also showed adaptability 
by updating content to reflect legislative changes, creating targeted content on emerging issues, 
and moving online during the COVID-19 pandemic. 

In the stakeholder survey, most Objective II activities scored around "effective", while areas 
such  as  representative  actions,  financial  services  awareness,  and  consumer  education  tools 
scored between "neutral” and “effective". These findings, supported by interviews and focus 
groups,  suggest  a  need  for  more  targeted  and  context-specific  approaches  to  education  and 
awareness efforts. 

Objective III: Consumer rights and redress  
Objective III aimed to support evidence-based consumer policy and improve access to redress. 
It focused on enhancing understanding of consumer behaviour and market dynamics through 
behavioural studies, market research, and policy-relevant analysis. Funded activities included 
studies,  seminars,  databases,  and  IT  tools,  such  as  the  Online  Dispute  Resolution  (ODR) 
Platform, and support for networking, and capacity-building for national ADR entities through 
grants, ADR Expert Group meetings and the ADR Assemblies in 2018 and 2021.  

Behavioural  and  market  studies  significantly  strengthened  the  evidence  base  for  EU 
consumer  policy.  A  flagship  study  estimated  that  EU  consumers  incurred  EUR  20.3-58.5 
billion in annual detriment across six markets, providing a methodology later adopted by the 
OECD47.  Sectoral  studies  informed  policies  across  energy,  digital  markets,  and  financial 
services, see Table 6. 

Table 6: Overview of the main studies and their policy impact 

Study Title / Topic 

Main Findings 

Utilisation / Policy Impact 

Cost (in EUR) 

Measuring 

Consumer 

Developed  methodology  for  quantifying 

Adopted  by  OECD;  used 

in  policy 

Detriment in the EU 

consumer harm. 

development on enforcement priorities. 

Pre-contractual 

Information 

and  Billing 

in 

the  Energy 

Market 

Unclear 

billing 

reduces 

consumer 

Informed the Electricity Market Directive and 

switching and market engagement. 

consumer information initiatives. 

450,000 

300,000 

46 Final evaluation report, unpublished.  
47 https://www.oecd.org/en/publications/measuring-consumer-detriment-and-the-impact-of-consumer-
policy_0c2e643b-en.html  

18 

 
 
 
Study Title / Topic 

Main Findings 

Utilisation / Policy Impact 

Cost (in EUR) 

Residential  Prosumers  in  the 

Identified barriers to participation in green 

European Energy Union 

energy. 

Supported 

EU 

energy 

consumer 

empowerment  policies; 

clearer  billing 

300,000 

boosted switching behaviour. 

Study on the Sharing Economy 

Risks  for  consumers  on  peer-to-peer 

Fed 

into  Digital  Markets  Strategy  and 

platforms; the rise of access-based models. 

platform regulation debates. 

Online  Market  Segmentation 

Found evidence of price discrimination and 

Used in shaping transparency provisions in e-

and Personalised Pricing 

lack of transparency. 

commerce legislation. 

350,000 

550,000 

Functioning  of  the  Real  Estate 

Market for Consumers 

Barriers 

in 

cross-border 

property 

transactions;  major  disparities  across 

Member States. 

Supported  calls  for  standardised  procedures 

and consumer protection in real estate. 

300,000 

Functioning of M-Payments for 

Highlighted  privacy  and 

transparency 

Contributed 

to  review  of 

the  Payment 

Consumers 

issues. 

Services Directive. 

Retail  Financial  Services  and 

Identified  misleading  advertising  and 

Cited  in  revisions  to  the  Consumer  Credit 

Barriers to Cross-Border Credit 

access obstacles. 

Directive. 

Mystery  Shopping  Survey  on 

Geo-blocking  limited  consumer  access  to 

Used  as  evidence  for  the  Geo-blocking 

Geo-Blocking 

services. 

Regulation. 

280,000 

400,000 

500,000 

Source:European Commission procurement database. 

Stakeholders  in  the  mid-term  evaluation  confirmed  these  studies  were  effective  and 
recommended more targeted, smaller-scale research, a practice now adopted in the 2021–2027 
SMP. According to focus groups, the studies directly shaped EU and national policymaking, 
and supported legislation and enforcement. They also influenced how consumer vulnerability 
is  understood,  reinforcing  the  concept  of  bounded  rationality,  and  moving  away  from  the 
assumption of fully rational consumer behaviour. 

Despite substantial efforts, the Programme did not significantly improve consumer access to 
simple, low-cost redress mechanisms, particularly ADR. The ODR platform, launched in 2016 
and  fully  funded  by  the  Programme,  aimed  to  provide  a  single  EU  entry  point  for  online 
consumer disputes. While communication efforts were highly effective, actual use remained 
limited. Backed by a 2015 ex-ante evaluation, the ODR campaign exceeded expectations: it 
reached 21 million users on Facebook, 9 million on Twitter, and generated 13 million video 
views,  four  times  the  forecast.  The  platform  saw  2.8  million  visits  in  2019,  with  200,000 
monthly  users,  and  a  Christmas  campaign  achieved  6.2  times  more  clicks  than  expected. 
Activities also included branding, communications support, and outreach to traders, but these 
efforts did not translate into widespread platform use. 

Despite high visibility and traffic, the ODR platform saw very low conversion rates. Between 
2016 to 2021, only about 1% of submitted complaints, fewer than 200 annually, were resolved 

19 

 
 
via ADR48. This remained unchanged despite technical upgrades and improved guidance.  In 
response, the Commission proposed repealing the ODR Regulation in October 2023, with the 
repeal  adopted  in  December  2024  and  set  to  take  effect  in  July  2025,  citing  the  platform’s 
persistent underperformance and limited added value. 

Barriers to effectiveness extended beyond the ODR platform. While the Programme funded its 
launch and extensive awareness campaigns, its overall impact on access to redress was limited 
by the fragmented transposition of the ADR Directive across Member States. Compliance with 
ODR obligations varied significantly by country, sector, and trader size, with larger traders and 
some  Member  States  engaging  more,  while  smaller  traders  often  lacked  awareness  or 
willingness to participate. Inconsistent implementation, complex cross-border procedures, and 
limited monitoring further weakened ADR reliability. Despite improvements to the platform’s 
interface  and  communications,  these  systemic  issues  remained  unresolved  during  the 
Programme period. 

Some stakeholder responses to the Call for Evidence expressed critical views on enforcement 
and redress mechanisms under Objective IV. Organisations such as  Next Energy Consumer 
(NEC), DECO (Portugal), ITM (Poland), MSPCA (Malta), and individual citizens (e.g. from 
Germany) raised concerns about limited access to justice and ineffective ADR mechanisms, 
especially  for  vulnerable  consumers.  NEC  cited  structural  barriers  such  as  low  trader 
participation and lack of trust in redress tools. DECO and ITM noted slow and inconsistent 
enforcement, while MSPCA highlighted a lack of responsive authorities in cross-border cases. 
These concerns indicate that while the Programme provided tools like  CPCS and ECC-Net, 
some stakeholders found practical redress outcomes lacking, particularly in high-risk sectors 
or for underrepresented consumers. They underline the need to clarify the Programme’s role 
versus Member State responsibilities and highlight persistent gaps not reflected in indicator 
data. Funding for ADR activities also underperformed. While 50 ADR grants were awarded 
between 2018 and 2020, the budget was not fully absorbed. Key barriers included the 50% co-
financing  requirement  and  administrative  burden,  especially  for  smaller  ADR  bodies. 
Simplification  efforts  had  limited  effect.  However,  from  2022,  the  successor  funding 
programme,  the  SMP  increased  the  EU  co-financing  to  90%  and  streamlined  applications, 
leading to a notable increase in uptake. ECCs also contributed to the Objective III by informing 
consumers  about  ADR  options  and  ODR  platform.  They  did  so  through  awareness-raising 
campaigns on their national websites and social media channels, or physical stands in major 
European cities e.g. around Black Friday, Christmas period or summer sales, etc. Many ADR 
entities  were  awarded  grants  to  raise  awareness  on  out-of-court  dispute  resolution  e.g. 
conferences, TV and radio slots, etc. 

The  analysis  of  Objective  III  indicators  shows  mixed  performance  in  facilitating  consumer 
redress. Of the three  core indicators, only  Indicator 1 (number of ODR  complaints) met its 
target, with 147,000 submissions by 2020, showing high initial uptake. However, Indicator 2 
(proportion of unresolved ECC cases referred to ADR) reached just 24%, well below the 75% 
target, and Indicator 3 (proportion of consumers acting on a problem) remained at 67%, missing 
the 90% target (see Table 7). The broad definition of “complaint” in Indicator 3 (e.g. contacting 
the seller, not just formal redress) limits its relevance for assessing ADR/ODR effectiveness. 

48 Report from the Commission to the European Parliament, the Council and the European Economic and Social 
Committee  on  the  application  of  Directive  2013/11/EU  on  alternative  dispute  resolution  for  consumer 
disputes and Regulation (EU) No 524/2013 on online dispute resolution for consumer disputes.  

20 

 
 
 
More detailed platform-level data reveal deeper shortcomings: in 2020, although 50% of ODR 
cases were cross-border, 89% were closed automatically after the 30-day legal deadline, and 
only  1%  reached  an  ADR  body.  Most  complaints  were  either  refused  by  traders  (6%)  or 
withdrawn by consumers (4%), reflecting low trader participation, a persistent challenge also 
noted in the mid-term evaluation. Wider outcome indicators also confirm limited progress. The 
share of consumers who found ADR “easy to use” remained flat (46% in 2014 and 45% in 
2020), while satisfaction with ADR dropped from 68% in 2014 to 50.9% in 2018. In contrast, 
confidence in online shopping improved, suggesting that while access to redress mechanisms 
increased, trust, visibility, and practical usability did not. These results underscore the need for 
stronger  trader  engagement,  better  incentives  for  ADR  participation,  and  clearer,  targeted 
indicators to assess the real-world impact of funded redress tools. 

Table 7: Overview of progress (indicators for potential wider effects – Objective III) 

Baseline  (annual 
average   

Evaluation 
(annual 
2014-20)  

period 
average 

Final status   

(2020 
unless 
otherwise stated)  

Progress made   

Indicator  

2011-13)  

Percentage  of  consumers 
who  agree  that  it  is  easy  to 
settle  disputes  with  retailers 
providers 
and 
through 
out-of-court 
body  

service 
an 

48%  

are 

Percentage  of  consumers 
who 
satisfied  with 
complaint handling of those 
who complained to an ADR 
body  

57%  

43.9%a,*  

45%  

a 

average 

-on 
slight 
decline, but the proportions 
in 2016 and 2018 may have 
skewed 
results  by 
including  an  average  for 
out-of-court  and  through 
the courts.  

the 

62.6%b  

50.9% (2018)  

average 

an 
+on 
improvement,  but 
there 
was a dip in 2018 to 50.9% 
and  no  figure  reported  for 
2020.  

Percentage  of  consumers 
who feel confident shopping 
online in their own country / 
in other EU countries  

2012:  59% 
36%  

/ 
67.6%b / 47.4%b  

69.4% (2018)  

++significant improvement 
in  consumer  confidence  to 
shop online domestically or 
with other EU countries but 
no 
for 
2020.  

reported 

figure 

Key ++ = significant improvement made; + = improvement made; 0=stable; - = negative trend; --=significant 
decline.  

Notes: Averages calculated on basis of the available annual data  
a For the years 2014, 2016, 2018 and 2020. In 2016 and 2018 this was only reported as an average proportion 
of agreement (“Strongly agree” and “Agree”) with statements that it is easy to settle disputes with retailers and 
service  providers  through  "an  out-of-court  body"  and  "the  courts",  so  it  was  not  possible  to  record  only  the 
proportion who stated that it is easy to settle disputes out-of-court  
b Average of the years 2014, 2016 and 2018 as this metric was not reported for 2020 in EC, 2023e  
(*) Averages calculated on basis of the available annual data.  
Source:  Compilation  based  on  year-on-year  differences  indicated  in  the  Commission’s surveys  of  consumers’ 
attitudes toward cross-border trade and consumer protection (2014, 2016, 2018, 2020), see  notes to the figures 
below for question wording.  

21 

 
 
The Consumer Conditions Scoreboard 202149 provides a useful summary of how consumers’ 
perception  of  consumer  rights  evolved  over  the  period  of  2014-2020.  Highlights  from  this 
report, in terms of the average proportion of EU consumers with a stated perception in the year 
2020,  all  representing  a  significant  improvement,  were:  70%  trusted  public  authorities  to 
protect  consumer  rights; 80%  agreed  that  retailers  and  service  providers  generally  respect 
consumer  rights; 66%  trust  non-governmental  consumer  organisations  to  protect  consumer 
rights; 63% feel confident purchasing goods or services via the internet from retailers or service 
providers in their country; and 43% feel confident purchasing goods or services via the internet 
from retailers or service providers in an/other EU country.  

In the area of consumer redress, the 2021 Consumer Conditions Survey reported that in 2020, 
47% of consumers agreed that it is easy to settle disputes with retailers and service providers 
through an out-of-court body (a significant increase during the survey years 2014-2020). In 
contrast, only 35% agreed that it is easy to settle disputes with retailers and service providers 
through the courts (no significant change during the survey years 2014-2020). Additionally, 
27% of respondents in 2020 reported a high level of knowledge of consumer rights, though no 
comparable  data  were  available  for  earlier  years,  limiting  longitudinal  analysis.   However, 
persistent  barriers  remain.  While  77%  of  consumers  did  not  experience  any  problems  with 
online purchases in 2020, consistent with previous years, there was a notable increase in the 
proportion of consumers who encountered a problem but did not act to resolve it. Among the 
main reasons cited were perceptions that it would take too long (50%), the amount at stake was 
too small (43%), or that a satisfactory outcome was unlikely (38%). These findings suggest 
that despite improved trust and legal frameworks, perceived inefficiencies and low expected 
returns  continue  to  discourage  consumers  from  pursuing  redress,  particularly  for  minor 
disputes.  Taken  together,  Scoreboard  results  confirm  that  the  Programme  helped  build 
consumer trust and awareness, but its impact on redress behaviour remained limited, hindered 
by structural issues such as complexity, delays, and low trader accountability. 

The Citizens’ Energy Forum, co-organised by DG JUST and DG ENER, plays a strategic 
role in promoting transparency and consumer participation in EU energy policy. Established in 
2008,  it  brings  together  200–300  stakeholders,  including  citizens,  regulators,  and  industry 
representatives. The Forum supports the development and enforcement of consumer rights in 
the energy sector by fostering informed consumer engagement, facilitating dialogue between 
regulators and industry, and helping to ensure that consumer perspectives are integrated into 
energy market rules and redress mechanisms, particularly in the energy transition. The 2018 
edition  in  Dublin  focused  on  themes  such  as  energy  poverty,  renewables,  and  consumer 
protection, in line with the 'Clean Energy for All Europeans' and 'New Deal for Consumers' 
packages. 

The Financial Services User Group (FSUG) is a consultative body established and funded 
under the Programme to ensure that the perspectives of users, particularly consumers, SMEs, 
and civil society, are reflected in EU financial services policymaking. It directly contributes to 
the Objective III by strengthening consumer rights in financial services by providing expert 
advice 
informs  regulatory  frameworks,  and  redress  provisions.  Composed  of 
representatives from consumer organisations, trade unions, academics, and other non-industry 

that 

49 2008-2023 Consumer Conditions Scoreboards are published here: https://commission.europa.eu/strategy-and-

policy/policies/consumers/consumer-protection-policy/evidence-based-consumer-policy/previous-
consumer-conditions-scoreboards-and-surveys_en  

22 

 
 
 
stakeholders, the FSUG provides structured input to the Commission through position papers, 
policy recommendations, and responses to consultations. It meets several times per year. FSUG 
has had a measurable influence on policy development. Its  recommendations are frequently 
cited  in  Commission  documents,  including  consultation  papers,  impact  assessments,  and 
legislative  proposals.  For  instance,  its  input  on  credit  advertising  and  transparency  was 
reflected in  the Commission’s review of the consumer credit framework. Its  2018 paper on 
"Consumer Protection in the Digital Age" helped shape the Digital Finance Strategy, ensuring 
consumer  safeguards  in  innovation.  Similarly,  the  2019  report  on  "Financial  Inclusion" 
informed  the  European  Financial  Inclusion  Strategy,  especially  concerning  access  for 
vulnerable groups such as the unbanked and digitally excluded.  

Stakeholder  feedback  from  the  Programme’s  online  survey  placed  the  effectiveness  of 
Objective  III activities just below “effective” but  above “neutral”, the lowest  average score 
across the four objectives. This suggests that while activities under Objective III were viewed 
positively, their impact may have been less visible or more uneven than others. An exception 
was the Citizens’ Energy Forum, which received a “very effective” score. Four activity types 
were rated close to “effective”, while two scored nearer “neutral”: communication campaigns 
and studies, training, actions or events, indicating scope for improvement in these areas. When 
asked about the benefits of Objective III in their own countries, respondents rated most impacts 
around “mostly achieved,” with three areas closer to “neutral”: awareness of financial services, 
teacher resources for consumer education, and information on national consumer markets. 

Overall,  while  Objective  III  strengthened  EU-level  frameworks  for  consumer  redress  and 
improved coordination among ADR bodies, its practical impact at national level was uneven. 
Persistent barriers, such as low trader participation in ODR, fragmented implementation of the 
ADR Directive, and varying national commitment, limited improvements in consumers’ ability 
to resolve disputes quickly and at low cost. These findings point to the need for more consistent 
national  implementation,  targeted  measures  to  increase  trader  engagement,  and  stronger 
monitoring of ADR performance in future programming. 

Objective IV: Enforcement  
According to the mid-term evaluation, the Programme was successfully achieving Objective 
IV  by  enhancing  cooperation  among  national  enforcement  bodies  and  improving  access  to 
enforcement-related  advice  for  consumers.  The  CPC  Network  significantly  expanded  its 
activities,  becoming  a  cornerstone  of  EU  consumer  law  enforcement.  Mechanisms  such  as 
mutual  assistance,  information  exchange,  and  coordinated  sweeps  became  more  effective, 
although handling times remained lengthy in some cases. CPC enforcement sweeps between 
2014  and  2020  addressed  sectors  such  as  e-commerce,  travel  services,  online  reviews,  and 
misleading green claims, with non-compliance rates ranging from 42% to 78.7%. Most traders 
corrected identified issues voluntarily, with enforcement action required in fewer than 18% of 
cases. These actions contributed to notable improvements in compliance in targeted sectors. 
Consumer  trust  in  authorities  and  retailers  increased,  while  reported  consumer  problems 
slightly declined. 

However,  challenges  remained.  Stakeholders  highlighted  limited  staffing  and  financial 
resources in national authorities and the increasing complexity of products, services, and online 
marketplaces as key obstacles. The CPC Network provided EU-wide added value by promoting 
harmonised  enforcement,  supporting  less-resourced  authorities,  and  enabling  best  practice 
exchange.  Stakeholder  support  was  strong:  15  of  19  responding  national  enforcement 

23 

 
 
authorities rated joint actions as “effective”, and sweeps were similarly well-regarded. Survey 
and interview feedback confirmed the CPC’s relevance and the value of coordinated EU-level 
enforcement.  Capacity-building  efforts  were  also  central.  Tools  like  the  CPC  Knowledge 
Exchange  Platform  (CPC  Wiki)  and  CPC  Market  Watch  enhanced  cooperation  and  risk 
monitoring. The E-Enforcement Academy, launched in 2016, trained enforcement officials on 
digital investigation skills through a mix of online and scenario-based modules.  Performance 
monitoring  via  the  Single  Market  Scoreboard  showed  positive  results:  66%  of  enforcement 
requests were handled within 12 months (exceeding the 60% target), and 79% of information 
requests  were  processed  within  three  months  (vs.  a  50%  target).  These  results  demonstrate 
improved efficiency and responsiveness across the CPC Network. 

Enforcement cooperation and capacity building under Objective IV were core components 
of the Programme’s effectiveness. From 2014 to 2020, a total of 859 exchanges of enforcement 
officials  took  place,  promoting  standardised  enforcement  practices  and  cross-border 
knowledge  sharing.  Survey  responses  from  7  participating  national  authorities  rated  the 
exchange programme as effective (4) or very effective (2), with one neutral. While participation 
varied by country, feedback confirmed its value. 

Training  for  enforcement  officials  and  the  judiciary  also  received  moderate  to  high 
effectiveness  ratings,  reinforcing  the  importance  of  capacity-building.  Other  networking 
activities, such as Presidency events and policy conferences, supported coordination efforts: 
23 out of 24 respondents rated them as effective or very effective. The CPC Regulation (in 
force since 2020) further strengthened enforcement coordination mechanisms. According to 
the mid-term evaluation, two-thirds of retailers believed that public authorities actively monitor 
compliance  with  consumer  legislation,  an  observation  confirmed  by  national  and  EU-level 
interviews  and  stakeholder  feedback.  Sweeps  were  widely  seen  as  effective  by  CPC 
stakeholders, although some noted uneven implementation across countries. Capacity-building 
tools, such as peer exchanges, training modules, CPC Wiki, and IT systems, were credited with 
reinforcing enforcement capabilities and enabling cross-border cooperation. 

Interviews  with  enforcement  stakeholders  (including  CPC  authorities,  CSN,  ECCs,  BEUC, 
ADR bodies, and Eurochambres) highlighted significant progress in capacity building, joint 
enforcement, and knowledge sharing. However, gaps remain, especially in tackling complex, 
evolving  issues  like  greenwashing,  where  additional  training  and  coordination  are  needed. 
Survey  respondents  gave  an  average  score  of  4.2  ("Effective")  for  enforcement-related 
activities. ECCs were rated closest to "Very Effective", and most respondents indicated that 
intended benefits were “mostly achieved” in their country, showing strong alignment with the 
Programme’s objectives. 

Performance indicators under Objective IV present a mixed picture of enforcement cooperation 
within the CPC Network (see Table 2). The number of information exchange requests dropped 
from 132 (2014) to 25 (2020), despite a brief rebound in 2018. Enforcement measure requests 
peaked  at  198  (2017)  but  fell  to  113  (2020),  indicating  limited  net  progress.  Alerts  shared 
within  the  CPC  network  consistently  remained  below  the  annual  target  of  82.  Timeliness 
indicators also underperformed: enforcement requests handled within 12 months fell short of 
the 60% target  and were later removed under the revised CPC Regulation (EU) 2017/2394. 
Similarly, information requests handled within 3 months never reached the 50% target, ranging 
between  23%  and  38%.  While  the  Programme  supported  training,  coordination,  and  CPC 

24 

 
 
operations, it did not fund operational enforcement, limiting its direct influence on these results. 
The  worsening  of  some  indicators  reflects  structural  challenges  across  Member  States, 
particularly limited staffing, uneven prioritisation, and legal fragmentation. 

In terms of wider impacts, consumer trust in public authorities rose slightly from 60% to 64% 
(2014–2018), though overall market functioning remained stable, with 20–25% of consumers 
reporting  issues  warranting  complaints  (see  Table  8).  Retailers’  perception  of  enforcement 
declined, with only 66% in 2018 believing authorities monitor compliance, down from 75% 
(2011–2013 baseline). These results underscore the need for stronger national capacity, better 
CPC coordination, and improved data monitoring under the new regulatory framework. 

Table 8: Overview of progress (indicators for potential wider effects – Objective IV)  

Indicator  

Baseline 
(annual 
average  2011-
13)  

Percentage  of  consumers  who  saw  public 
authorities 
their  rights  as  a 
consumer  

to  protect 

60%  

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

62%  

Percentage of consumers who encountered at 
least  one  problem 
they  considered 
legitimate to complain about   

that 

2012: 25%  

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

75%  

Evaluation 
period  (annual 
average  2014-
2020)  

Final 
(2020 
otherwise 
stated)  

status 
unless 

Progress made   

64%a,*  

61.8% (2018)   0 fairly stable  

72.7%a  

71.3% (2018)  

++significant 
improvement  

21.4%b  

23%  

0 fairly stable  

66%c  

65.5% (2018)   0 stable  

Key ++ = significant improvement made; + = improvement made; 0=stable; - = negative trend; --= significant decline  
Notes: Averages calculated on basis of the available annual data.  

a.  Data was available for 2014, 2016 and 2018; the figure for 2020 was not published in 2023e  
b.  Data was available for 2014 and 2020, for 2016 and 2018 this was reported as a discrete figure but as a composite indicator, 

so was calculated by subtracting from 100% the proportion of consumers experiencing no problems.  

c.  Data was available for 2014, 2016 and 2018, the survey of retailer’s attitudes to cross-border trade and consumer protection 

seems not to have been undertaken in 2020.  

(*) Averages calculated on basis of the available annual data.  

Source: Compilation based on the year-on-year differences indicated in the Commission’s 2014 – 2020 survey of 
consumers’  attitudes  toward  cross-border  trade  and  consumer  protection,  e.g.  2018  survey  available  here: 
https://op.europa.eu/en/publication-detail/-/publication/2094456a-ecc2-11ea-b3c6-01aa75ed71a1/language-en, 
and  the  2014  -  2018  Commission’s  survey  of  retailer’s  attitudes  toward  cross-border  trade  and  consumer 
protection,  available  here:  https://op.europa.eu/en/publication-detail/-/publication/f716f97d-ecc2-11ea-b3c6-
01aa75ed71a1/language-en.  

The European Consumer Centres (ECCs) played a key role in advancing Objectives II, III, 
and IV, supporting consumers with cross-border issues through advice, complaint handling, 
and referrals to ADR procedures. Their communication efforts also included newsletters, social 
media,  and  public  outreach.  Performance  indicators  show  growing  engagement:  targets  for 
consumer contacts have been met since 2018, and website visit targets since 2014. Complaints 

25 

 
 
handled  nearly  doubled  between  2014  and  2020,  with  over  60,000  COVID-related  cases 
addressed  in  2020  alone.  Stakeholders,  including  CPC  authorities,  ECCs,  DG  JUST,  and 
consumer organisations, consistently rated ECCs as very effective, a view echoed in the online 
survey,  where  ECCs  received  the  highest  effectiveness  rating  of  all  actions  evaluated. 
Respondents also confirmed that ECCs had mostly achieved their national-level benefits. ECCs 
contributed to knowledge sharing and networking via participation in strategy groups, ECC-
Net events, and international conferences, reinforcing their role in consumer and enforcement 
support. However, coordination gaps persist. While ECC intelligence triggered CPC actions 
(e.g.  on  subscription  traps),  feedback  remained  one-way:  ECCs  rarely  received  updates  on 
follow-up actions. Cooperation with ADR bodies also lacked structured interaction. Despite 
participation  in  the  Consumer  Policy  Network,  ECCs  had  limited  influence  on  policy  or 
enforcement  strategy.  Recommendations  include  establishing  formal  feedback  mechanisms 
and increasing joint CPC–ECC actions to close coordination gaps. 

4.2 Efficiency 

The  evaluation  assessed  the  costs  of  financing  various  activities  under  the  Programme  and 
attempted  to  compare  these  with  monetised  benefits  where  such  data  was  available.  The 
absorption  rate  stands  at  87.4%  indicating  a  relatively  high  level  of  budget  execution, 
particularly  considering the diversity of implementing entities (e.g. consumer organisations, 
enforcement authorities, and research bodies) and the cross-border nature of many activities. 
This strong absorption rate reflects the Programme’s capacity to allocate funds, though some 
variations existed between objectives  and funding instruments.  Notably, grants  required co-
financing  and  were  subject  to  administrative  complexities,  which  sometimes  limited 
participation  or  delayed  implementation.  Both  quantitative  and  qualitative  benefits  were 
identified  as  part  of  the  effectiveness  criterion.  However,  due  to  limited  quantified  data  on 
benefits, both the mid-term evaluation and this evaluation have faced constraints in analysing 
the Programme's efficiency. Funded activities were not subjected to econometric evaluations 
to establish causal links between their outputs and the actual benefits produced, relying instead 
on the assumption that they contributed to some extent to the Programme's overall impacts.  
This section highlights a selection of activities to illustrate the Programme's efficiency. The 
absence of harmonised cost/output tracking limited the possibility of calculating benefit-cost 
ratios. However, proxies such as alerts triggered, resolved cases, and stakeholder-reported time 
savings were used to estimate relative efficiency. 

Simplification measures introduced in the Programme aimed to increase efficiency and reduce 
administrative burden, especially for recurrent and large-scale activities. A key measure was 
the shift from grants to procurement contracts, particularly under Objective I (Product Safety). 
From  2019  onward,  funding  for  coordinated  market  surveillance  and  testing  activities—
previously  supported  via  grants,  was  implemented  through  procurement  mechanisms, 
including high-value contracts under the CASP framework. This shift enabled the Commission 
to achieve greater centralisation, faster implementation, and better control over deliverables, 
while  also  reducing  the  co-financing  and  reporting  burden  on  national  authorities.  Other 
simplification  efforts  included:  centralising  IT  infrastructure  development  and  maintenance 
(e.g. for RAPEX/Safety Gate, the ODR platform, CPCS, and ECCNet2) under procurement 
contracts,  allowing  for  multi-annual  planning  and  more  efficient  supplier  management; 

26 

 
 
 
streamlining awareness campaigns; focusing grant funding on EU-level capacity-building (e.g. 
BEUC, ANEC) and essential operating support for the ECC-Net 

Objective I: Product safety 
Safety  Gate/RAPEX  notifications,  which  alert  national  authorities  and  the  public  about 
dangerous non-food products found on the EU market, have proven to be cost-effective. This 
is because of these notifications’ impact on the number of accidents and ill-health consequences 
avoided thanks to Member States follow-up actions upon receiving the notification. While it is 
not possible to estimate the overall avoided detriment for consumers due to the lack of detailed 
data on number and severity of avoided accidents, benefits would likely outweigh the costs of 
Safety  Gate/  RAPEX.  This  conclusion  is  further  supported  by  the  broader  estimate  from 
product-related accidents, which amounts to approximately EUR 76.6 billion per year. Of this, 
about 15%, equivalent to EUR 11.49 billion annually, is deemed preventable through improved 
product  design,  safety  features, or better usage instructions50. This  highlights the significant 
potential of preventive systems like Safety Gate/RAPEX in reducing avoidable harm.   
More than 2 000 notifications of products posing serious risk were reported each year between 
2014 and 2020, alerting other Member States about dangerous products and thus enabling them 
to undertake follow-up action. The study supporting this evaluation estimated the cost-benefit 
ratio of Safety Gate/RAPEX notifications51. Using an illustrative example of an unsafe item 
having a 4:100 000 likelihood of causing injuries of any severity, the cost of avoided accidents 
from  the  items  withdrawn  in  other  Member  States  as  follow  up  to  the  annual  number  of 
notifications (2 000 notifications x 109 000 items52) results in an estimate of annual number of 
8  700  injuries  of  any  severity  being  prevented.  The  monetary  cost  of  these  accidents  being 
prevented can be estimated at EUR 61 million per year. It is estimated that on average around 
EUR  1.2  million  per  year  was  spent  on  Safety  Gate/RAPEX  from  the  Programme.53  This 
suggests that the avoided costs of injuries caused by unsafe products is likely to have exceeded 
the  Programme’s  annual  contribution  to  Safety  Gate/RAPEX  (the  cost/benefit  ratio  for  the 

50 Study to support the preparation of an evaluation of the General Product Safety Directive as well as of an impact 
its  potential  revision,  Final  report,  March  2021,  Civic  Consulting  (available: 

assessment  on 
https://commission.europa.eu/document/download/23c95b7c-9e2c-4338-9b97-
5f1762a059dd_en?filename=gpsd-final-report-part1-eval.pdf )  

51 Study to support the Ex-post evaluation of the Consumer Programme (2014-2020), p. 55. 
52 The 109 000 estimated number of items removed from the  market is calculated by multiplying the average 
number  of  reactions  per  notification  (1.87)  by  the  average  number  of  products  affected  per  notification 
(58,300) (Civic, 2020; EC, 2021). The EUR 61 million in accident cost savings is derived from an estimate 
of 8,700 prevented injuries of any severity per year, based on the assumption that an unsafe product has a 
4:100,000  likelihood  of  causing  injury.  The  average  cost  per  accident  is  estimated  at  EUR  6,960,  which 
includes healthcare costs (EUR 610), productivity losses (EUR 160), quality of life losses (EUR 2,580), and 
premature  death  costs  (EUR  3,610)  (Civic,  2020).  The  total  annual  cost  savings  is  thus  calculated  as: 
8,700×6,960=61,000,0008,700 \times 6,960 = 61,000,0008,700×6,960=61,000,000. These figures provide an 
indicative assessment of the benefits of Safety Gate/RAPEX notifications in reducing consumer detriment. 
However, given the limitations in available data, they should be interpreted as broad approximations rather 
than precise values. 

53 A total of EUR 38.6 million were committed to Objective I with an estimate of 22% of commitments for Safety 

Gate/ RAPEX. 

27 

 
 
 
above estimate being close to zero [0.02] based on full injury costs, and around 1:7.5 when 
using a more conservative preventable injury cost of EUR 1 045 per injury.54  

Safety  Gate/RAPEX  has  also  led  to  increased  efficiency  of  product  safety  enforcement 
throughout the EU by enabling Member States to share alerts about products posing a serious 
risk and follow-up notifications. The costs beyond the direct costs of implementation of the 
activities,  such  as  the  costs  of  recalling  products  notified  through  Safety  Gate/RAPEX  are 
deemed  by  this  evaluation  as  generally  affordable,  considering  the  stakeholder  categories, 
market  surveillance  authorities  and  manufacturers.  For  national  market  surveillance 
authorities, the removal of unsafe products from the market is their core activity which is made 
more  efficient  by  receiving  alerts  from  other  Member  States.  For  economic  operators,  it 
levelled the playing field with regard to compliance and safety standards, such as in reduction 
in differences between Member States). 

Some  activities  improved  collaboration  between  the  Member  States  resulting  in  resource 
savings  due  to  improved  information  sharing  and  prevention  of  duplication.  Safety 
Gate/RAPEX, joint actions and Coordinated Activities on the Safety of Products (CASPs) 
helped  deal  with  lower  capacity  of  Member  States,  administrative  burden  (through  the 
development of templates and procedures), and the avoidance of duplication of effort, thus also 
increasing the quality of notifications. Interviewees comprising representatives from national 
market surveillance authorities, EU-level officials involved in product safety coordination, and 
members of the Consumer Safety Network agreed that funded joint actions and collaborative 
projects,  such  as  CASPs  have  proved  valuable  in  areas  such  as  surveillance,  especially  for 
Member  States  with  limited  budgets  for  product  testing.  CASPs  support  Member  States  by 
reducing the administrative burden of testing procedures with the role of a cross-Member State 
coordinator. CASPs offered a high return on investment. For example, CASP 2019 tested 652 
toys,  with  75%  being  found unsafe or  non-compliant, resulting  in  170  Safety  Gate/RAPEX 
alerts.  The  average  EU  contribution  per  tested  product  was  estimated  at  EUR  450,  making 
CASP a cost-effective intervention when considering the potential harm  prevented55. CASP 
testing (activity) directly generated outputs in the form of laboratory-verified unsafe products, 
which  fed  into  Safety  Gate/RAPEX  alerts  (output),  contributing  to  market  withdrawals, 
consumer warnings, and long-term behavioural adjustments in supply chains (outcomes and 
impacts). While the improved indicators and increased trust align with Programme activities, 
causality cannot be definitively established due to the lack of a control group and the influence 
of  external  market  and  regulatory  dynamics.  Nonetheless,  triangulated  evidence  supports  a 
credible contribution claim. 

54 The study applied a sensitivity analysis operating with a likelihood of 1:1,000,000 (likelihood of being struck 
by a lightning).54 It is reasonable to assume that an item notified for serious risk has a greater likelihood of 
causing injury than 1:1,000,000. This approach results in an estimated 220 injuries being avoided by follow-
up  action  to  Safety  Gate/RAPEX  notifications  with  an  associated  monetary  value  of  €1.5  million,  still 
exceeding the Programme’s annual contribution to Safety Gate/RAPEX (i.e. a cost/benefit ratio of 0.8). 
55  Data  sourced  from  the  CASP  2019  final  report  (see  Annex  VIII  to  the  SWD)  and  project-level  financial 
breakdowns  in  the  external  supporting  study.  CASP  2019  tested  652  products;  funding  per  CASP  action 
ranged between EUR 250,000 and EUR 400,000. This results in an estimated cost per tested item of EUR 
450 to EUR 600, depending on the action. See also: Ex-post evaluation study (Section 3.3), which reports 
~75% non-compliance and high follow-up enforcement. 

28 

 
 
 
Objective  II:  Consumer  information  and  education,  developing  the  evidence  base  and 
support to consumer organisations 
BEUC  has  contributed  across  a  wide  range  of  consumer  protection  areas,  including  policy 
development,  consumer  education,  and  enforcement  coordination.  It  has  also  supported 
national consumer organisations, particularly those with limited resources, by providing know-
how and facilitating their input into EU-level policymaking. While a detailed cost-effectiveness 
analysis was not carried out, stakeholders consulted in the evaluation, such as representatives 
of BEUC, national consumer organisations (some of which are BEUC members), officials of 
DG JUST, and national authorities engaged in the programme, considered the level of funding 
allocated  to  BEUC  to  be  broadly  proportionate  to  the  scope  and  scale  of  its  activities  and 
outputs. This perception was based on BEUC’s visible role in representing consumer interests 
at EU level, its contribution to legislative and policy files, and its capacity-building work with 
national  organisations.  As  such,  the  assessment  of  proportionality  reflects  a  qualitative 
judgement informed by interviews and programme documentation rather than a quantified cost-
benefit analysis. BEUC receives funding from membership fees, EU budget (funded projects 
and  operating  grant),  foundation  funded  projects  and  other  income.  Interviewees  noted  that 
external  donors  allow  BEUC  to  increase  the  impact  of  the  activities,  for  example,  by 
contributing to sustainability issues, energy efficiency of buildings, and clean energy.  In 2020, 
BEUC’s income was EUR 5 899 806, of which around EUR 4 million covered staff costs. A 
third  of  that  income  (33%)  was  from  an  operating  grant  from  the  Programme,  which  is  its 
primary source of income. Based on project documentation, the main activity funded by the 
Programme operating grant is representation of member consumer organisations, policy input, 
and undertaking ‘enforcement actions’. Furthermore, the operating grant funds some topical 
activities which are chosen on the basis of market concerns, e.g. payment fraud and abuse. The 
majority (90%) of BEUC’s work involved preparation and dissemination of position papers; 
press releases and press briefings in order to raise public awareness; and active participation in 
conferences and hearings.56 An increase of the BEUC’s operating grants from 201857 onwards 
allowed BEUC to expand and develop several workstreams. For instance, in 2018, a BEUC 
project contributed to developing, implementing and sharing reinforced IT tools and platforms 
at the disposal of the less affluent members to reach out to consumers in their countries. BEUC 
also  supported  and  coordinated  its  members  in  developing  strategies  to  enhance  their 
enforcement activities.  

Other consumer awareness and education activities, including Consumer Champion and 
Consumer  PRO  have  resulted  in  outputs  (e.g.  consumers  being  trained  or  consumer 
organisations’ capacity building), but evidence of lasting impacts is lacking. For the first two 
years of the of the Consumer PRO (2019-20), EUR 1.47 million was committed to activities 
such as needs analysis, train-the-trainers, local and regional trainings and an exchange of best 
practice seminar.  

Objective III: Consumer rights and redress 
It was found that behavioural studies are cost-effective as they set the agenda and contribute 
to  the  policy  development  process.  The  average  project  budget  for  behavioural  studies  was 
relatively large compared to other procurement projects (in the range EUR 279 000 to EUR 

56 BEUC 2018 Work Programme annual activity report. 
57 The maximum grant amount was EUR 1 400 000 peryear between 2015 and 2017 and increased to EUR 1 750 

000 in 2018 and EUR 2 000 000 per year in 2019 and 2020. 

29 

 
 
 
550  000)  and  together  they  accounted  for  approximately  EUR  3.2  million  (2%  of  the 
Programme  budget).  Understanding  what  informs  people's  behaviour  is  essential  for 
policymaking but requires a careful study design and collection of primary data, meaning that 
behavioural studies typically require significant resources and time. Focus group discussions 
indicated that the project costs for behavioural studies reflected the specified scope of projects, 
which were often broad, as well as the methods needed to undertake them, which resulted in 
lengthy projects. In this evaluation, citation analysis method was used as an indirect indicator 
of cost-effectiveness.  It demonstrated that behavioural studies funded under the Programme 
were referenced in key Commission impact assessments and evaluations, thereby supporting 
the  legislative  development  process.  For  example,  the  study  on  the  digitalisation  of  the 
marketing and distance selling of retail financial services was cited in the evaluations of the 
Directive on Distance Marketing of Financial Services (DMFSD) and  the Consumer Credit 
Directive (CCD) undertaken in 2020. The study on the transparency of online platforms was 
also referenced in two impact assessments on proposals: for a regulation on promoting fairness 
and  transparency  for  business  users  of  online  intermediation  services;  and  as  regards  better 
enforcement and modernisation of consumer protection rules. The study on online personalised 
pricing that cost EUR 550 000 fed directly into impact assessments for the Digital Services 
Act,  enabling  evidence-based  rules  on  algorithmic  transparency  across  the  EU  e-commerce 
sector. 

The  2023  Impact  Assessment  of  the  proposed  ADR  Directive58  noted  the  difficulty  in 
quantifying  costs  to  stakeholder  groups  but  concluded  that  ADR  remains  the  most  cost 
advantageous system both for traders and consumers, but also for Member States if going to a 
court. The same report also identified potential cost savings. Facilitating digitalisation of ADR 
and  the  use  of  modern  technologies  and  exchange  of  good  practice  funded  by  ADR  grants 
contributed to increasing the cost-effectiveness of the funded entities. The cost-effectiveness 
of ADR grants as a whole, however, was hampered by the Programme’s inability to disburse 
the full allocations. Low uptake of ADR grants was primarily due to the 50% co-financing rate 
and complex administrative requirements. In addition, many eligible entities lacked dedicated 
fundraising or project staff, limiting their capacity to apply. This mismatch between funding 
design and stakeholder reality severely reduced the efficiency of Objective III grant delivery. 

The low success rate of the ODR platform remained broadly constant between 2016 and 2021, 
regardless of the technical/design improvements and information campaigns with only around 
1% of all claims made through the ODR platform proceeding to ADR, i.e. on average less than 
200 cases per year. For this reason, the ODR platform was assessed as not cost-effective. Still, 
some of the activities may have been cost-effective with regard to their specific objectives. For 
example, ODR platform awareness campaigns were effective and evidenced in terms of cost 
per click generated, compared with similar campaigns. Therefore, with an average of only ~1% 
of  147,000  ODR  complaints  resulting  in  an  ADR  outcome  between  2016  and  2020,  and 
operational costs exceeding EUR 2 million over the period, the platform's cost-effectiveness 
remained very low, estimated at over EUR 1,300 per resolved case. The evaluation concluded 
that  due  to  structural  limitations  in  the  ODR  design  (e.g.,  double  opt-in  and  low  trader 
coverage), the system could not deliver proportional value relative to its operational cost, even 
after technical improvements. 

58https://commission.europa.eu/system/files/2023-10/SWD_2t023_335_1_EN_impact_assessment_part2_v3.pdf 

30 

 
 
 
Objective IV: Enforcement 
A significant share of Programme funding was committed to activities related to actions under 
Objective IV. EUR 60.7 million (35% of funds) was split between activities under action 10 
(EUR  16.2  million),  which  includes  the  CPC  Network,  and  ECC-Net  (EUR  44.5  million), 
funded under action 11. The Programme funding committed to action 10 increased from EUR 
0.98 million in 2014 to a peak of EUR 4.35 million in 2019.  Funding allocated to the CPC 
authorities for CPC capacity-building was through grants. The grants were used to cover costs 
related to personnel and training, equipment and infrastructure, operational costs, such as travel 
and meeting expenses and studies, surveys, and other research activities. Overall, a mix of large 
and small value grants were awarded, the latter awarded since 2018. While the Programme did 
not perform a dedicated cost-benefit analysis for CPC capacity-building grants, qualitative data 
and  stakeholder  feedback  indicate  that  the  CPC  Network's  interventions  were,  after  the 
simplification  measures,  considered  cost-effective.  This  model  also  enabled  more  direct 
Commission  oversight  and  facilitated  the  development  of  standardised  tools  and  services, 
reducing administrative burdens and increasing consistency.  

A cost-benefit analysis of the ECCs confirmed a high level of efficiency and proportionality 
under  the  Programme.  ECCs  were  predominantly  funded  by  grants,  with  EU  co-financing 
averaging 55, with those MS of low GDP receiving 67%. Annual EU funding rose from EUR 
5.2 million in 2015 to EUR 7 million in 2020, supporting 29 ECCs, including centres in Iceland, 
Norway, and the UK (until its withdrawal in 2020). France and Germany received the highest 
total allocations (EUR 7.7 million each), due in part to their leadership of joint projects. Iceland 
received the lowest funding (EUR 29 977–38 845). While most countries received a similar 
number  of  grants,  grant  values  varied  considerably.  Operational  costs  were  generally  co-
financed  equally  with  national  authorities,  with  higher  co-financing  rates  for  lower-GDP 
Member  States  and  joint  projects  (renamed  ‘EU  Dimension  Activities’  in  2024)  benefiting 
from a 54% co-financing rate. From 2014 to 2020, the ECC caseload nearly doubled, from 94 
000  to  168  000  contacts.  Efficiency  improvements  included  ECC-Net  2  (streamlining  case 
handling), expanded social media outreach, and partnerships with media outlets. As a result, 
the average cost per case declined from EUR 70 in 2014 to EUR 40 in 2020, demonstrating 
strong and growing cost-efficiency, even before the COVID-related demand surge. 

The level of ECC funding did not always align with caseloads or resolution times. For instance, 
the UK ECC had a high caseload but was not among the top five funded centres, likely due to 
contextual rather than efficiency differences. In contrast, France and Germany ranked high in 
both  funding  and  caseloads,  partly  due  to  their  leadership  in  high-value  joint  projects  that 
attracted  additional  co-financing.  To  assess  proportionality,  the  evaluation  estimated  the 
monetised value of ECC services. Using findings from the Commission’s consumer detriment 
study,  which  identified  financial  loss,  time  lost,  and  psychological  stress  as  key  factors,  a 
simplified  estimation  was  developed.  Although  ECC  data  do  not  perfectly  match  these 
categories, the number of complaints handled between 2014 and 2020 allowed for a reasonable 
approximation. 

31 

 
 
 
During  this  period,  ECCs  dealt  with  130  781  complaints59.  Applying  an  average  financial 
detriment  value  of  EUR  46.90  per  problem60  results  in  an  estimated  EUR  6.13  million  in 
avoided or recovered financial losses. In addition, the average consumer reportedly spends 5.8 
hours  dealing  with  such  issues.  Assuming  this  time  was  saved  through  ECC  support  and 
applying  an  average  EU  hourly  wage  rate,  the  estimated  time-saving  benefit  amounts  to 
approximately  EUR  17.3  million.  Although  psychological  stress  was  not  monetised  in  this 
calculation, it remains a significant factor. Approximately 57% of respondents to the consumer 
detriment  study  reported  experiencing  ‘quite  a  lot’  or  ‘extreme’  stress  due  to  problematic 
purchases. Extrapolating from this proportion, around 74 000 of the consumers supported by 
ECCs  during  the  evaluation  period  likely  benefited  from  reduced  psychological  stress  as  a 
result of receiving assistance. Taken together, the monetised benefits to consumers, financial 
recovery and time saved, are estimated at roughly EUR 23.4 million over the evaluation period. 
When  compared  to  the  EUR  44.5  million  in  Programme  funding  committed  to  ECCs,  this 
suggests a substantial return, though not a one-to-one financial match. Importantly, the estimate 
does not capture the full range of benefits delivered by ECCs, such as improvements to cross-
border enforcement, trust-building among consumers, and institutional development through 
shared  tools  and  practices.  In  particular,  joint  projects  helped  generate  efficiency  gains  by 
reducing  duplication  and  allowing  ECCs 
infrastructure  and 
methodologies. Overall, ECCs are considered a success story within the Programme, delivering 
both tangible consumer benefits and broader systemic value that support the case for continued 
EU-level investment. 

leverage  common 

to 

4.3 Coherence 
The  Programme  was  designed  to  be  internally  coherent  across  its  four  specific  objectives. 
Activities  funded  under  each  objective  were  intended  to  support  complementary  tools,  data 
flows, or actions, thereby reinforcing the broader goals of consumer protection, enforcement, 
and  information.  Internal  coherence  was  evident  in  several  cross-cutting  initiatives—for 
example, how behavioural studies under Objective III were informed by research funded under 
Objective  II, or how data collected by ECCs (Objective  IV) supported  enforcement  actions 
under the CPC Network. Training tools such as the e-Enforcement Academy were designed to 
serve multiple objectives, including product safety, market surveillance, and redress. Overall, 
the  evidence  confirms  the  mid-term  evaluation’s  conclusion:  the  Programme  was  both 
internally  and  externally  coherent.  While  isolated  areas  showed  room  for  improvement, 
particularly  in  better  linking  networks  like  ECCs  and  the  CPC,  there  were  no  significant 
contradictions  or  overlaps  identified.  The  Programme’s  priorities  and  funded  actions  were 
viewed as complementary and synergistic.  

Internal coherence 

59 The figures used in this calculation are based on the number of “Normal complaints”  reported by ECCs pre 
2018 and “Complaints” from 2018 onwards, both of which required intermediation.  It is noted that other 
complaints not requiring intermediation were handled in addition to these, referred to under categories of 
“questions” or “information requests” or “simple complaints”. 

60 This is estimated by initially calculating the average detriment pre- and post redress across all sectors for each 
of face-to-face and online transactions.  These averages were utilised to identify the overall average difference 
in detriment pre and post redress for each of face-to- face and online transactions.  The average of these two 
figures is EUR 46.90 

32 

 
 
 
The Programme’s design and delivery mechanisms ensured that the objectives supported one 
another through interlinked activities.   

Objective I: Product safety 
Safety Gate/RAPEX was well integrated with broader enforcement and surveillance efforts. 
For example, the online marketplaces that are signatories to the Product Safety Pledge have 
committed to regularly check Safety Gate/RAPEX and remove dangerous products from their 
websites61, a model now embedded in the General Product Safety Regulation. CASP activities 
further operationalised Safety Gate/RAPEX insights through joint surveillance activities (some 
of  looking  at  cooperation  with  the  customs  authorities  or  online  market  surveillance),  risk 
assessments  and  communication  campaigns.62  Initiatives  such  as  Safety  Gate/RAPEX 
improvements, and international workshops work together to enhance the overall effectiveness 
of consumer safety measures. The collaboration between Safety Gate/RAPEX, Member States 
and Consumer Safety  Network was also  highlighted by interviewed stakeholders,  including 
representatives from national market surveillance authorities, members of the CSN, and EU-
level officials, as essential for improving data gathering, streamlining risk communication, and 
aligning national surveillance efforts. For example, CASP 2019 and 2020 generated 170 and 
218 Safety Gate/RAPEX alerts, respectively, illustrating clear functional linkage. In parallel, 
the Information and Communication System for Market Surveillance (ICSMS) ensured that 
test results,  surveillance  actions, and  Safety  Gate/RAPEX notifications could  be linked  and 
tracked by authorities across Member States. By 2020, over 90% of Member State authorities 
were  using  ICSMS  in  connection  with  Safety  Gate/RAPEX  notifications.  These  systems 
worked  synergistically  to  avoid  duplication  in  testing,  consolidate  findings,  and  streamline 
responses. 

Capacity-building tools such as the e-Enforcement Academy further reinforced this coherence 
by providing training modules on risk assessment and surveillance techniques. Several smaller 
or newer national authorities noted that CASP participation and training improved their ability 
to report into Safety Gate/RAPEX and use ICSMS effectively, thereby improving consistency 
in surveillance quality and enabling common enforcement responses. The alignment between 
CASP,  Safety  Gate/RAPEX,  and  market  surveillance  also  ensured  that  alerts  triggered 
coordinated  withdrawals  across  Member  States,  enhancing  the  systemic  efficiency  of  the 
product safety framework. 

Objective  II:  Consumer  information  and  education,  developing  the  evidence  base  and 
support to consumer organisations 
BEUC’s activities were found to align closely with the Programme’s priorities. Its 2018 Work 
Programme,  for  instance,  reflected  a  wide  scope  consistent  with  Objectives  II,  III,  and  IV, 
covering consumer rights and enforcement, digital rights, financial services, food safety and 
information, energy markets, healthcare, and product safety. This evaluation identified multiple 
synergies between BEUC and other activities, particularly those under Objective IV on ECCs. 
BEUC and ECCs work on similar topics and frequently exchange expertise and information. 
BEUC’s role in bridging national and EU-level consumer priorities was supported by regular 
coordination with CPC authorities and participation in the Consumer Policy Advisory Group 

61 See Product Safety Pledge progress reports, available at  https://commission.europa.eu/publications/progress-

reports-implementation-product-safety-pledge_en  

62 See CASP 2019, 2020 and 2021: https://ec.europa.eu/safety-gate/#/screen/pages/casp  

33 

 
 
 
(CPAG).  BEUC  also  maintains  a  long-standing  cooperation  with  ANEC,  the  European 
consumer  voice  in  standardisation.  At  the  national  level,  consumer  organisations  often 
participate  in  both  BEUC  and  ANEC  working  groups,  contributing  to  policy  development, 
technical standards, and regulatory dialogue. 
Awareness  campaigns  and  consumer  education  activities  played  a  cross-cutting  role  in 
supporting  the  effectiveness  of  interventions  across  the  Programme  and  aligning  with  the 
broader EU consumer acquis. Their relevance stems from the fact that the  success of many 
policy tools, such as those promoting product safety (Objective I), alternative dispute resolution 
(Objective III), and the services provided by the ECCs (Objective IV), depends significantly 
on consumers being informed, engaged, and empowered. Consumer PRO serves as a strong 
example of internal coherence, illustrating how education and training efforts extended into 
related Programme areas. Between 2019 and 2021, it developed theoretical training modules 
on general consumer law, digital rights and sustainability, aimed at improving the professional 
capacity of consumer protection professionals across MS.63,64 Stakeholders noted it became a 
recognisable  brand  by  creating  synergies  with  other  initiatives,  particularly  Consumer  Law 
Ready,  with  shared  trainers  and  materials,  including  newsletters  and  training  resources. 
Consumer PRO also collaborated with BEUC, leveraging its expertise for workshops like the 
Communications and Social Media session, thereby ensuring alignment and consistency across 
initiatives.65 

Objective III: Consumer rights and redress 
Objective  III  supported  the  other  three  objectives  of  the  Programme  by  generating  policy-
relevant  evidence  and facilitating consumer access  to ADR mechanisms.  A key tool in  this 
regard was the series of behavioural and market studies, which provided insights into consumer 
behaviour, market functioning, and regulatory needs.  These studies not only underpinned legal 
and policy proposals (e.g. the revised Consumer Credit Directive), but also had cross-cutting 
impacts,  informing  product  safety  communications  (Objective  I),  feeding  into  awareness 
campaigns  and  training  modules  (Objective  II),  and  supporting  enforcement  coordination 
(Objective  IV).  Their  influence  extended  across  EU-level  networks.  Interviews  conducted 
during the evaluation,  including  with representatives  from  national  consumer organisations, 
EU  policymakers,  and  members  of  the  Consumer  Policy  Network,  confirmed  that  the 
dissemination  of  behavioural  evidence  played  an  important  role  in  initiating  discussions, 
raising awareness, and shaping enforcement priorities across objectives. While the proposed 
amendments to the ADR Directive in 2023 fall outside the evaluation period, its content reflects 
continuity of themes identified during the 2014–2020 Programme, notably the need for closer 
coordination  between  ECCs  and  ADR  bodies.  This  coherence  was  also  reflected  in  the 
Commission’s proposal to designate ECCs as ADR contact points, a move seen by stakeholders 
as building  on the groundwork laid by the Programme.  Feedback from  stakeholders further 
revealed  that  improved  sharing  of  best  practices,  especially  where  complaints  handling, 
enforcement referrals, or consumer rights education overlapped, was necessary. For example, 

63https://www.beuc.eu/consumer-pro-boosting-professionals-consumer-protection#theoretical-background-

documents  

64 For example, the general consumer law background documents contain a number of references to EU consumer 
protection legislation. See, for example, the  Austrian and Czech translations of the general consumer law 
brochure  here:https://www.beuc.eu/consumer-pro-boosting-professionals-consumer-protection#theoretical-
background-documents  

65 Consumer PRO, Final Report 2018-2023, unpublished.  

34 

 
 
 
findings  from  behavioural  studies  on  consumer  inertia  in  financial  services  or  confusion  in 
energy markets were used in ECC campaigns (Objective IV) and BEUC advocacy (Objective 
II). In this way, Objective III acted as both a source of evidence and a connector, helping to 
translate  consumer-facing  insights  into  actionable  policy,  effective  outreach,  and  more 
accessible redress systems, thereby reinforcing the collective impact of the Programme. 

Objective IV: Enforcement 
Activities funded under Objective IV, particularly the CPC Network and ECC Net, were found 
mutually  reinforcing  and  contributed  to  a  coherent  enforcement  system  that  addressed  both 
collective consumer interests and individual assistance needs. While the CPC Network pursued 
systemic infringements of EU consumer law, ECCs provided direct, cross-border support to 
consumers. Their collaboration helped bridge the gap between policy enforcement and day-to-
day consumer redress. Cooperation between the ECC-Net and the CPC Network included joint 
actions,  such  as  coordinated  response  during  the  Covid-19  pandemic,  when  rogue  traders 
marketed fraudulent health products. Similar collaborations were reported in areas subscription 
traps and other unfair commercial practices,  where consumer complaints  gathered by ECCs 
informed CPC sweeps and investigations, linking Objective IV and III effectively. Synergies 
also existed with BEUC, particularly in organising regular meetings and aligning advocacy on 
enforcement  gaps  or  systemic  issues.  Coherence  in  training  and  capacity  building  was 
supported through initiatives such as the e-Enforcement Academy, which was also relevant to 
Objective I, especially regarding product safety enforcement. The Academy provided market 
surveillance  and  consumer  enforcement  authorities  with  access  to  harmonised  training 
materials, tools, and practices that strengthened cooperation and consistency across borders. 

Despite  these  achievements,  several  stakeholders,  particularly  from  ECCs,  indicated  that 
synergies  with  the  CPC  Network  could  be  further  strengthened.  Suggestions  included 
increasing  the  number  and  scope  of  joint  activities,  such  as  joint  monitoring  of  emerging 
commercial  practices  or  coordinated  responses  to  pan-European  scams.  The  flow  of 
information between ECCs and ADR bodies was also seen as suboptimal, with feedback loops 
often described as one-directional. During focus groups, ECC representatives noted that while 
they regularly share intelligence with  CPC and  ADR bodies, they rarely receive systematic 
updates  or  coordinated  follow-up,  limiting  the  potential  to  close  the  policy-practice  loop. 
Overall, Objective IV demonstrated solid internal coherence and contributed to enhancing the 
overall  enforcement  ecosystem,  yet  further  integration  and  feedback  mechanisms  between 
networks and actors could significantly improve its impact. 

External coherence 
External  coherence  assesses  the  complementarity  and  alignment  of  the  Programme  with 
broader EU consumer policy objectives and other relevant Union initiatives. Throughout the 
2014-2020 period, the objectives and eligible actions of the Programme were coherent with 
Article 169 of the Treaty on the Functioning of the European Union and with Article 38 of the 
Charter of Fundamental Rights of the European Union which enshrines the right to a high level 
of consumer protection, reinforcing the Programme’s role in safeguarding consumer rights and 
promoting fair market practices across the EU. It supported the practical implementation of the 
vision outlined in the Consumer Agenda 2012 and Digital Single Market Strategy 2015. There 
was also a significant degree of coherence between the objectives of the Programme and the 
2018 New Deal for Consumers. Since the last set of commitments under the Programme were 

35 

 
 
made  in  2020  and  their  implementation  thus  goes  beyond  2020,  the  evaluation  assessed 
coherence with the 2020 Consumer Agenda66 that builds on the 2012 agenda and addresses 
new and emerging  challenges, including  the Covid-19 pandemic, digital transformation  and 
green transition.  

The Programme contributed to the EU's strategy for smart, sustainable, and inclusive growth 
by  improving  consumer  confidence,  market  transparency,  and  regulatory  coherence—all 
essential  enablers  of  competitiveness.  By  reinforcing  trust  in  digital  and  cross-border 
transactions,  supporting  informed  decision-making,  and  enabling  dispute  resolution,  the 
Programme reduced friction in internal market functioning and stimulated both consumer and 
business activity. 

Several  Programme  elements  were  directly  conducive  to  smart,  sustainable  and  inclusive 
growth  by  strengthening  the  position  of  consumers  as  informed,  empowered  and  protected 
actors in the internal market: 1. Actions supporting digital transition (e.g. consumer education 
on  digital  rights,  ODR,  BEUC’s  work  on  platform  regulation)  improved  digital  market 
confidence. 2. CASP and RAPEX helped create safer product markets, thereby fostering a fair 
competitive environment. 3. ADR and ECC-Net contributed to business competitiveness by 
reducing costly litigation and improving customer satisfaction. 4. Capacity-building for SMEs 
through Consumer Law Ready reduced compliance burdens and increased trust in SME offers. 

Less growth-relevant areas included awareness campaigns with limited long-term behavioural 
effects  and  the  underperforming  ODR  platform,  which  had  lower  practical  uptake  by 
consumers and traders. 

Overall,  the  aims  and  objectives  of  the  Programme  complemented  those  of  the  other  EU 
funding  programmes,  contributing  to  a  comprehensive  approach  to  consumer  protection, 
environmental sustainability, social equality, and market integration within the EU. This also 
suggests  that  the  activities  funded  under  the  Programme  were  coherent  with  broader  EU 
policies. In relation to broader EU policies, Article 12 of the TFEU commits the EU to taking 
consumer  protection  requirements  into  account  in  ‘defining  and  implementing  other  Union 
policies  and  activities’.  A  significant  degree  of  coherence  between  the  Programme  and  the 
following programmes has been identified: 

•  With the LIFE Programme, coherence was found in environmental goals, particularly 
in promoting sustainable consumption practices and eco-labelling, though LIFE’s focus 
is broader and more environmentally anchored. 

•  With the Connecting Europe Facility (CEF), coherence emerged particularly in the 
digital  domain,  where  CEF  funded  digital  infrastructure  while  the  Programme 
supported  digital  consumer  empowerment,  such  as  through  ODR  and  consumer 
education on digital rights. 

•  With  the  Rights,  Equality  and  Citizenship  (REC)  Programme,  coherence  was 
ensured through internal coordination within DG JUST, avoiding duplication despite 
thematic  overlap.  While  REC  covered  broader  social  issues,  it  included  a  specific 
objective  on  consumer  rights.  Funded  actions,  averaging  EUR  1.3  million  annually, 
were small-scale and complementary, focusing on digital consumer protection, capacity 

66 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52020DC0696  

36 

 
 
 
building, and analysis. Examples include a study on digital content products67, updates 
to the Consumer Law Database, and SME training on consumer and marketing law. 

In  addition,  there  was  documented  coherence  with  international  obligations,  particularly 
through  cooperation  with  OECD  and  participation  in  ICPEN  (International  Consumer 
Protection and Enforcement Network) via the CPC Network. These partnerships helped ensure 
that EU consumer protection standards contributed to and benefited from global best practices. 
The  mid-term  and  final  evaluations  both  concluded  that  the  Programme’s  actions  were 
generally well coordinated with national and EU-level interventions, supporting shared goals 
such as high consumer trust, effective enforcement, and alignment with the Single Market’s 
digital and green transitions. 

Objective I: Product safety 
The external coherence of coordinated market surveillance and alerts was high, as these actions 
supported enforcement of, and disseminated data relevant to, on a wide range of EU product 
safety legislation, including GPSD and various sectoral directives. The Safety Gate/RAPEX 
system  served  as  a  key  instrument  in  sharing  information  on  dangerous  non-food  products 
across  Member  States  and  with  external  partners, 
thereby  supporting  consistent 
implementation of EU law and enhancing market surveillance coordination. The exchanges of 
enforcement  officials,  through  joint  actions  and  CASP  projects,  contributed  to  a  more 
harmonised  and  coherent  approach  to  surveillance  across  the  EU.  International  cooperation 
reinforces the external coherence of the Programme by ensuring that EU actions in product 
safety and market surveillance are aligned with broader international frameworks and partner 
initiatives.  The  Commission’s  active  participation  in  global  fora  such  as  the  OECD  Global 
Recall System and International Product Safety Week not only supports the exchange of best 
practices,  but  also  ensures  complementarity  with  global  efforts.  Examples  such  as  the 
reciprocal data-sharing with Health Canada and the adoption of EU-led product safety pledges 
by other jurisdictions underscore the Programme’s alignment with international norms and its 
contribution to globally coherent consumer protection frameworks. These efforts help avoid 
duplication, enhance trust, and ensure consistent standards in an increasingly interconnected 
global marketplace.  

Objective  II:  Consumer  information  and  education,  developing  the  evidence  base  and 
support to consumer organisations  
The support provided to BEUC, as the main grant beneficiary under Objective II, significantly 
enhanced the external coherence of the Consumer Programme. BEUC acted as a key interface 
between EU consumer policy and both internal and external policymaking arenas. At the EU 
level, it ensured alignment between consumer protection priorities and broader strategies such 
as  the  Digital  Single  Market,  the  Green  Deal,  and  the  Capital  Markets  Union  by  actively 
contributing  to  legislative  processes  and  coordinating  the  input  of  its  national  members. 
Externally,  BEUC  represented  EU  consumer  interests  in  global  fora  including  the  OECD, 
ICPEN,  and  the  Trans-Atlantic  Consumer  Dialogue,  ensuring  consistency  between  the 
Programme’s objectives and evolving international consumer policy standards. Its cooperation 
with ANEC and regular interaction with ECCs and CPC authorities further reinforced policy 
alignment across standardisation, enforcement, and redress mechanisms. Other activities under 
Objective  II  also  demonstrated  a  high  degree  of  external  coherence.  Programmes  such  as 

67 See https://commission.europa.eu/system/files/2017-10/study-consumer-digital-content-products_en.pdf  

37 

 
 
 
Consumer PRO, Consumer Law Ready, and various awareness campaigns directly supported 
cross-cutting  EU  priorities  related  to  digital  rights,  SME  engagement,  and  sustainable 
consumption. These actions were often complementary to initiatives funded under other EU 
programmes,  including  REC,  Horizon  2020,  and  EU4Health.  By  equipping  consumers, 
professionals, and small businesses with practical tools and knowledge, these activities helped 
operationalise broader EU policy goals and strengthened the integration of consumer interests 
across environmental, economic, and digital policy domains. 

Objective III: Consumer rights and redress 
Behavioural studies were initially pioneered in consumer policy and are now used by a range 
of other policies within the Commission, demonstrating strong external coherence and cross-
policy relevance. Support  for ADR provides  practical  and efficient  means for consumers to 
enforce their rights without resorting to the often costly and time-consuming court system, thus 
reinforcing the overall coherence with the EU consumer rights acquis and contributing directly 
to EU goals of access to justice and effective enforcement. Moreover, ADR grants provided 
under  the  Programme  were  coherent  with  other  EU  policy  frameworks,  such  as  the  Small 
Business  Act  for  Europe68,  which  encourages  the  reduction  of  administrative  burdens  for 
SMEs.  By  promoting  effective  and  fair  resolution  of  consumer  disputes,  ADR  mechanisms 
helped foster trust in the Single Market, ensure a level playing field, and support sustainable 
growth.69 Feedback from interviews and focus group discussions with stakeholders, including 
ADR bodies, European Consumer Centres (ECCs), BEUC, national consumer organisations, 
and officials from DG JUST, confirmed that Programme’s actions are well-coordinated with 
national  consumer  policies.  In  particular,  national-level  decisions  on  ADR  implementation 
were  reinforced  by  EU-level  funding,  visibility,  and  knowledge  exchange,  improving  the 
consistency and reach of ADR solutions across Member States. 

Objective IV: Enforcement 
The funding provided under Objective IV was externally coherent with the overall EU legal 
framework.  The  activities  of  ECCs  contributed  to  key  Single  Market  goals,  by  enhancing 
confidence  in  cross-border  trade.  Certain  ECCs  led  joint  activities  (now  known  as  EU 
Dimension Activities) benefiting the whole of ECC-Net, while others produced policy position 
papers on pressing consumer issues, including geo blocking (2019), the right to repair, roaming 
charges,  and  aggressive  timeshare  sales  tactics.  These  papers  informed  and  influenced  key 
pieces of legislation, such as the revised Timeshare Directive (Directive 2008/122/EC) and the 
Regulation on Roaming Charges (Regulation (EU) 2022/612). The ECC-Net contributed to EU 
consumer policy through stakeholder consultations. For example, the network provided input 
during consultations by the European Parliament on the Digital Services Act, which resulted 
in  the  Digital  Services  Regulation  (entered  into  force  in  2022).  ECCs  also  contributed  to 
consultations  on  the  repeal  of  the  ODR  Regulation  and  the  review  of  the  Package  Travel 
Directive. At the national level, ECCs demonstrated external coherence by collaborating with 
sector-specific actors, such as civil aviation authorities on passenger rights, travel and hotel 
agents, trade unions, and major e-commerce platforms. These efforts complemented the work 
of  national  consumer  organisations,  reinforcing  the  EU’s  consumer  protection  architecture. 
Similarly,  enforcement  actions  undertaken  by  the  CPC  network,  especially  in  the  areas  of 
online and cross-border commerce, were externally coherent with broader EU priorities, such 

68 See, for example, https://single-market-economy.ec.europa.eu/single-market/single-market-act_en  
69 See, for example, https://ec.europa.eu/commission/presscorner/detail/en/ip_20_416  

38 

 
 
 
as the Digital Single Market Strategy. These actions helped strengthen consumer and business 
trust  in  e-commerce,  ensuring  alignment  between  enforcement  mechanisms  and  wider  EU 
digital and market integration goals. 

4.4 How did the EU intervention make a difference and to whom? 
The mid-term evaluation of the Programme highlighted that funded activities, such as Safety 
Gate/RAPEX, the CPC Network, ECC-Net  and support to  BEUC, have generated clear EU 
added value. This was particularly evident where actions complemented national measures by 
addressing  cross-border  challenges,  enabling  economies  of  scale,  or  creating  synergies  that 
could not have been achieved by Member States acting alone. The Programme facilitated more 
effective collaboration among national authorities, enabled the sharing of best practices, and 
allowed resources to be pooled to achieve common goals, contributions widely recognised as 
valuable by stakeholders responding to the survey and other consultations. 

The  EU  intervention  through  the  Programme  made  a  tangible  difference  to  European 
consumers, especially in cross-border contexts where national measures alone would have been 
insufficient. It provided tools, networks, and enforcement mechanisms that ensured consumers 
could  shop  more  safely,  resolve  disputes  more  easily,  and  access  reliable  information, 
regardless of where they lived. Activities such as Safety Gate/RAPEX, ECC-Net, CASP, and 
the CPC Network helped to harmonise protection levels across the Single Market, supporting 
trust  in  product  safety,  e-commerce,  and  redress.  Quantitative  and  qualitative  evidence 
confirms  that  consumers  were  the  primary  beneficiaries.  For  instance,  the  ECC-Net  is 
estimated  to  have  generated  at  least  EUR  23.4  million  in  direct  consumer  benefits  through 
complaints handled and guidance offered. Nevertheless, quantifying the difference or impact 
of the Programme on consumers remains challenging, quantifying the difference or impact of 
the Programme on consumers is challenging, as the Programme was not designed with a strong 
counterfactual evaluation framework, and many of its broader effects were not directly tracked. 
Equally,  the  Programme’s  impact  on  competitiveness  and  economic  growth  was  primarily 
indirect  and  not  always  quantifiable.  While  it  likely  contributed  to  a  fairer  business 
environment  and  more  efficient  markets,  especially  in  cross-border  trade,  the  evaluation 
acknowledges the difficulty in  attributing specific macroeconomic outcomes (e.g. increased 
GDP or innovation) directly to Programme actions. 

Stakeholders  consistently  emphasised  that  EU  support  was  essential  to  ensuring  consistent 
services across the Single Market and building consumer confidence, particularly in areas such 
as  product  safety,  cross-border  trade,  the  digital  economy,  and  e-commerce.  Specific 
achievements, such as the promotion of ADR mechanisms in sectors like telecommunications 
and postal services, were viewed as directly dependent on EU-level intervention. EU funding 
was  also  seen  as  critical  for  enabling  capacity-building,  training,  policy  development  and 
enforcement  actions.  Many  stakeholders  noted  that,  without  sustained  EU  support,  national 
public resources would likely have been insufficient to achieve similar outcomes, potentially 
resulting  in  fragmentation and weakened  consumer protection, especially  in  Member States 
with more limited capacity. However, some stakeholders expressed more critical or nuanced 
views.  These  included  concerns  about  uneven  access  to  consumer  protection  tools  across 
Member  States,  the  limited  practical  reach  of  certain  actions,  particularly  in  redress  and 
enforcement, and the underperformance of specific initiatives, such as the ODR platform. Civil 
society  and  consumer  organisations  also  pointed  to  areas  where  enforcement  could  be 
strengthened,  and  consumer  education  further  enhanced.  These  perspectives  underline  the 

39 

 
 
importance of ensuring that future actions are both inclusive and adaptable to national contexts, 
and that they respond to gaps in impact, especially in domains with weaker infrastructures. 

Compliant businesses also benefitted through improved legal clarity, a more level playing field, 
and increased consumer trust in cross-border transactions.  

Objective I: Product safety 
Sharing  and  streamlining  information  on  unsafe  consumer  products  through  Safety 
Gate/RAPEX identified by a Member State with other Member States avoided duplication in 
the identification and investigation of unsafe products and enabled a co-ordinated approach to 
market  surveillance  and  enforcement.  This  system,  coupled  with  harmonised  market 
surveillance, ensured that products met the same safety standards regardless of where they were 
sold,  reinforcing the integrity of the Single Market. By pooling resources and expertise, by 
sharing  risk  assessment  practices  and  building  trust  between  authorities,  CASP  projects 
reduced the administrative burden of testing, allowing for comprehensive testing and efficient 
market surveillance while avoiding duplication of efforts - achievements that would be difficult 
for Member States to attain individually. CASP also facilitated development of methodologies 
and ways of working that are based on good practices from around the EU through its horizontal 
activities.  

Objective  II:  Consumer  information  and  education,  developing  the  evidence  base  and 
support to consumer organisations 
EU-funded  awareness  initiatives,  such  as  campaigns  on  online  shopping  and  travel  or  e-
learning  platforms,  delivered  stronger  results  than  national  efforts  alone  by  ensuring  a 
harmonised approach and avoiding disparities in information quality across Member States. 
Centralised coordination also enabled more efficient use of resources. Interviewees, including 
representative from national consumer organisations, BEUC, and DG JUST officials noted that 
these initiatives improved consumer access to reliable information and support.  BEUC’s cross-
border  activities  added  clear  EU  value  by  supporting  national  consumer  organisations, 
coordinating collective redress, and contributing to high-profile cases such as Dieselgate and 
the Google Shopping antitrust appeal. Its policy input helped shape key initiatives like the New 
Deal for Consumers and informed EU rules on digital markets, financial services, and green 
claims. BEUC also supported enforcement by helping national organisations act on large-scale 
consumer harm and by contributing expertise to international forums. This strengthened the 
capacity of national organisations, particularly in smaller Member States, and ensured more 
consistent consumer protection across the EU.  

Within  Consumer  PRO  and  Consumer  Law  Ready  the  national  level  activities  benefited 
from  European level  support and coordination, ensuring a consistent level  of service across 
MS, while maintaining topics and training tailored to the MS. The Consumer PRO European 
workshops were well-received, with feedback noting that companies are international, and can 
use their resources more effectively by learning from other countries70. While EU interventions 
in the field of consumer education and information contributed to some improvement, it cannot 
be argued that the changes resulted directly from EU interventions, rather than other factors. 
Arguably, the impact of EU interventions is higher in the Member States with lower budgets 

70 Consumer PRO, Final report, BEUC 2023 

40 

 
 
 
 
dedicated  to  consumer  education  and  information.  However,  this  finding  would  have  to  be 
validated in further studies. 

Objective III: Consumer rights and redress 
Analysis of evidence related to Objective III confirms the added value of EU interventions. 
Persistent  disparities  in  the  results  of  the  Consumer  Conditions  Scoreboard71  highlight  the 
ongoing need for EU-level action. Behavioural studies contributed to this by sharing findings 
with  Member  States  that  lacked  the  capacity  to  conduct  such  research  themselves,  thereby 
supporting evidence-based policy and regulatory improvements. Additional EU added value 
came  through  the  commissioning  of  consumer  market  analyses,  legal  gap  assessments,  and 
application  reports,  which  informed  policy  development.  A  citation  analysis  showed  that 
behavioural studies were frequently referenced in documents supporting legislation and that 
some  recommendations  were  incorporated  into  EU  initiatives.  While  direct  evidence  of 
behavioural studies influencing enforcement or voluntary practices remains limited, there are 
indications that some enforcement actions, such as sweeps in the areas of consumer credit and 
online travel websites, have followed themes identified in behavioural studies. Similarly, the 
updated  Unfair  Commercial  Practices  Directive  (UCPD)  guidance72  includes  enforcement 
examples relevant to online platforms and social media. 

The Programme supported the implementation of the ODR Regulation and the ODR platform, 
by providing the necessary infrastructure and accompanying measures to promote their use. 
While  the  ODR  platform  established  a  unified,  centralised  channel  for  dispute  resolution, 
particularly  useful  for  Member  States  with  less  developed  systems,  the  low  success  rate  of 
resolved  cases  limited  its  overall  EU  added  value73.  The  Programme  also  supported  the 
implementation of the ADR Directive by funding activities that promoted access to quality out-
of-court resolution for consumers across the EU, especially in cross-border contexts. Grants to 
ADR entities typically ranged from EUR 10 000 to EUR 60 000, co-financing up to 50% of 
eligible  costs.  These  grants  supported  awareness-raising  activities,  case  handling 
improvements, staff training, and exchanges of best practices. In 2020, and again under the 
2024 call for proposals, the Programme allocated dedicated budgets (e.g. €1 million in 2024) 
to  enhance  the  capacity  of  ADR  entities  and  qualified  consumer  organisations.  Interviewed 
stakeholders,  including  representatives  of  ADR  entities  and  national  competent  authorities, 
highlighted  that  Programme-funded  networking  and  training  initiatives  helped  improve 
consistency and visibility of ADR mechanisms across Member States. Given that nearly half 
of complaints submitted via the ODR platform concerned cross-border cases, the Programme’s 
support for ADR capacity and cooperation provided meaningful EU added value, particularly 
in Member States where national systems remained underdeveloped. 

71 Consumer Conditions Scoreboard, Editions 2015 -2020 
72 Commission Notice – Guidance on the interpretation and application of Directive 2005/29/EC of the European 
Parliament and of the Council concerning unfair business-to-consumer commercial practices in the internal 
market, 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A52021XC1229%2805%29&qid=1640961745514   

available 

at: 

73 Only about of 1% (i.e. on average less than 200 cases per year) proceeded to ADR and the low success rate 
remained broadly constant between 2016 and 2021, regardless of the technical and design improvements to 
the ODR platform and information campaigns. See European Commission, 2023e. 

41 

 
 
 
 
 
Objective IV: Enforcement  
Activities funded under Objective IV related to the CPC Network have provided significant 
EU added value, which is widely acknowledged by stakeholders, including CPC authorities, 
ECCs, consumer organisations, ADR entities, DG JUST officials in both mid-term evaluation 
and  this  ex-post  evaluation.  The  Programme  enhanced  EU  value  by  complementing  and 
strengthening national measures, through joint actions, networking and training of enforcement 
officials.  In  addition,  the  Commission’s  coordination  activities  and  support  of  enforcement 
against  international  companies,  ensured  an  improved  level  playing  field  across  the  Single 
Market. Stakeholders explained that as e-commerce had been steadily growing and exploded 
in  2020,  it  made  the  Commission’s  coordination  and  tools  like  web  crawlers  even  more 
essential  for  CPC  authorities  to  respond  effectively.  They  also  emphasised  that  without 
financing and developing these tools, it would have been very difficult for Member States to 
react to the rapid changes in e-commerce and technological advancements. 

The  ECC-Net  played  a  crucial  role  in  cross-border  trade  by  assisting  with  disputes  and 
ensuring  consistent  service  across  all  centres.  Better-resourced  ECCs  supported  those  with 
fewer  resources,  allowing  for  a  uniform  level  of  service  regardless  of  location.  This 
collaboration ensured that consumers, wherever they were, received reliable assistance with 
cross-border issues, demonstrating the added value of the EU's support. ECC-Net's contribution 
to  consumer  confidence  extended  to  the  digital  economy.  By  helping  consumers  trust  the 
internal market, the network enabled cross-border purchases of goods and services, benefiting 
both consumers and businesses. This was validated by ECC representatives, who emphasized 
the importance of the network in building trust in cross-border trade and supporting the Single 
Market. Prior to joining ECC-Net, some centres74 only dealt with national complaints, but the 
network's resources allowed them to expand their support to cross-border issues. Thanks to the 
CPC Regulation, many ECCs were designated to send external alerts related to existing and 
potential  infringements  which  were  made  directly  available  to  the  CPC  network;  hence 
contributing to a more robust EU enforcement toolbox. 

4.5 Is the intervention still relevant? 
The evidence from this evaluation confirms the ongoing relevance and appropriateness of the 
Programme’s objectives. These objectives remain aligned with the needs of consumers across 
the EU, especially in light of the continued digitalisation, globalisation, and emergence of new 
market risks related to AI, sustainability, and cross-border digital commerce. Activities, such 
as market surveillance, consumer education and cross-border dispute resolution, continue to 
address systems risks and ensure fair treatment of consumers in an evolving internal market. 
The  increasing  demand  for  cross-border  dispute  resolution  and  the  need  for  stronger 
cooperation  among  enforcement  stakeholders  highlights  the  continued  relevance  of  the 
Programme, particularly in light of emerging e-commerce and AI-related safety concerns. The 
mid-term evaluation found the Programme addressed the needs and problems identified at the 
Programme’s  outset,  with  the  exception  of  limited  targeting  of  vulnerable  consumers.  The 
Programme’s  actions  were  able  to  adapt  to  the  changing  consumer  needs,  particularly  as 

74 For instance, the European Consumer Centre in the Czech Republic, operating under the Czech Trade Inspection 
Authority,  began  providing  assistance  with  cross-border  disputes  following  its  inclusion  in  ECC-Net. 
Similarly, the European Consumer Centre in Lithuania, established in 2005, started offering support for cross-
border  consumer  issues  as  part  of  the  network's  mission  to  enhance  consumer  confidence  in  the  internal 
market. 

42 

 
 
 
challenges evolved in digital and green policy areas. Results from the Consumer Conditions 
Scoreboard75, the thematic breadth of consumer complaints76 across the scope of Programme’s 
actions, as well as views of stakeholders, including national consumer organisations, consumer 
authorities, market surveillance officials, and representatives of the Commission show that all 
four  objectives  of  the  Programme  were  appropriate  and  still  relevant.  Further,  the  2020 
Consumer  Programme  Statement,  an  annual  programming  document  accompanying  the  EU 
draft  budget  for  the  year  202077,  highlighted  the  continued  relevance  of  the  Consumer 
Programme’s  objectives  under  the  new  consumer  strand  of  the  Single  Market  Programme, 
which retains the same four objectives. 

Product safety continues to be important due to structural shifts in consumer markets, including 
globalisation and digitalisation, which introduce new safety risks and enforcement challenges. 
Funding  facilitating  joint  testing  and  coordinated  enforcement,  e.g.  CASP,  improved  the 
knowledge  and  capacity  of  inspectors  and  strengthened  continued  cooperation  between 
Member  States  in  market  surveillance,  monitoring  products  and  ensuring  compliance  with 
safety  regulations.  CASP was adaptable and able to  focus on products  important  at  a given 
moment.  For  instance,  CASP  Corona2020  highlighted  the  relevance  and  the  agility  of  the 
Programme, such as improving market surveillance of Covid-19 related products. CASP also 
produced  an  EU  wide  communication  toolkit  on  Product  Specific  Activities  (PSA)  and 
Horizontal  Activities  (HA),  further  contributing  to  effective  testing  and  exchange  of  best 
practices.  Furthermore,  scientific  advice  provided  by  the  SCCS  committee  guided  risk 
assessments,  and  Safety  Gate/RAPEX78  addressed  dangerous  products  and  informed  and 
lack  awareness  of  Safety 
enforced  safety  regulations.  While  consumers  generally 
Gate/RAPEX,  it  does  influence  consumer  organisations,  who  use  Safety  Gate/RAPEX 
information when planning their product testing (such as selecting priority areas for the year 
ahead). Further, the EU product safety awards recognise best practices in consumer protection 
and  the  Product  Safety  Pledge  was  signed  by  five  major  online  marketplaces  and  also 
encourages proactive monitoring of SafetyGate.  

BEUC  played  a  crucial  role  in  ensuring  consumer  representation  and  adapting  to  crises 
encompassing  a wide range of cross-cutting  consumer needs  – from  digital rights,  financial 
services, energy markets, to sustainability. BEUC’s annual reports reflected the priorities of 
their  members  and  their  in-depth  knowledge  of  their  needs,  expectations,  difficulties  and 
complaints. The relevance of BEUC’s work also results from working across the Consumer 
Agenda, thus covering a broad range of consumer needs, while also bringing new issues and 
topics to the agenda. Examples of such topics that BEUC worked on in 2018 concerned issues 
such as Internet of Things and connected products, big data and Dieselgate79, while in 2020, 
BEUC  continued  to  address  emerging  and  complex  consumer  challenges,  including  digital 
fairness, greenwashing, the right to repair, and the consumer impacts of the Covid-19 crisis80.  

75 Consumer Conditions Scoreboards, editions 2015-2020.  
76 DFR, IPSOS, 2019 and IPSOS, 2020. 
77 European Commission, Draft General Budget of the European Union for the financial year 2020  – Working 
Document  Part  I:  Programme  Statements  of  Operational  Expenditure,  COM(2019)  400,  pp.  101–104. 
https://commission.europa.eu/document/download/a2cd479f-980d-4927-9863-
0d029b67eac6_en?filename=draft-budget-2020-wd-1_2019_en.pdf 

78  Economisti  Associati,  2016;  DG  JUST,  2021.  SafetyGateRAPEX  was  used  to  report  products  claiming  to 

protect consumers from viral infection during the COVID-19 pandemic. 

79 BEUC, Annual Report 2018, available at: https://annualreport.beuc.eu/year-2018/. 
80 BEUC, Annual Report 2020, available at: https://annualreport.beuc.eu/year-2020/. 

43 

 
 
 
The  relevance  of  capacity  building  initiatives, Consumer  PRO  and  Consumer  Law  Ready 
demonstrated adaptability (e.g. transitioning to online formats during the pandemic) and high 
satisfaction  rates.  Tools  such  as  training  sessions,  pre-tasks,  and  modular  learning  formats 
allowed for tailored national implementation and supported professional capacity-building. 

Behavioural studies were cited in the mid-term evaluation and in interviews for this evaluation 
as a key source of  evidence for  new trends  and  potential consumer detriment,  including  on 
online marketing  and pricing  techniques and dark patterns.  The  studies  were either directly 
cited in Commission policy documents and served as reference material in legislative drafting.  
Examples include the study on the digitalisation of the marketing and distance selling of retail 
financial services81, which was cited in the evaluations of the Directive on Distance Marketing 
of Financial Services (DMFSD)82 and the Consumer Credit Directive (CCD)83 undertaken in 
2020 and the study on strategies to improve the effectiveness of product recalls84, which was 
cited  in  the  Impact  Assessment  accompanying  the  proposal  for  the  General  Product  Safety 
Regulation  (GPSR)85.  Notably,  the behavioural  study on commercial practices  in  the digital 
environment  had  a  significant  impact  on  legislation  under  the  New  Deal  and  the  consumer 
agenda. The Commission was seen as a pioneer in behavioural studies, also considering the 
influence of these studies on Member States and organisations such as OECD. Interviewees 
indicated  that  the  supranational  nature  of  behavioural  studies  meant  their  findings  could  be 
shared and help initiate discussion and raise awareness, as well as inform future policy and 
actions.  

The  ODR  platform  and  ADR  entities  addressed  persistent  cross-border  redress  gaps. 
However, the ODR platform proved less effective due to structural limitations and overlap with 
private dispute resolution systems. ADR grants contributed to capacity-building, training, and 
awareness-raising  activities,  proving  relevant  especially  in  Member  States  with  limited 
national resources for redress. According to the 2011 Impact Assessment of the Programme, 
one of the key challenges in the enforcement of consumer legislation was the underutilisation 
of  the  CPC  Network,  with  persistent  gaps  in  cross-border  enforcement.  In  this  context, 
activities under Action 10 were highly relevant for achieving Objective IV of the Programme. 
The Programme also directly supported the implementation of legal obligations set out in the 
CPC  Regulation,  notably  by  maintaining  the  CPC  IT  tool,  an  essential  infrastructure  for 
coordinated  enforcement.  High  levels  of  non-compliance  by  online  traders  emerged  as  a 
particularly  pressing  problem  at  the  Programme's  inception  and  remained  so  throughout  its 

81 Civic Consulting, Study on the Digitalisation of the Marketing and Distance Selling of Retail Financial Services, 
2019.  

European 
Consumers, 
https://op.europa.eu/en/publication-detail/-/publication/9c891010-e88c-11ea-adf7-01aa75ed71a1 

Directorate-General 

Commission, 

Justice 

and 

for 

82  European  Commission,  Commission  Staff  Working  Document  –  Evaluation  of  the  Directive  on  Distance 
Marketing  of  Consumer  Financial  Services  (Directive  2002/65/EC),  SWD(2020)  254  final,  Brussels,  10 
December 2020. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52020SC0254 

83 European Commission, Commission Staff Working Document – Evaluation of the Consumer Credit Directive 
(Directive 2008/48/EC), SWD(2020) 253 final, Brussels, 10 December 2020. https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX:52020SC0253 

84  Civic  Consulting  and  London  Economics,  Behavioural  Study  on  Strategies  to  Improve  the  Effectiveness  of 
Product  Recalls,  European  Commission,  Directorate-General  for  Justice  and  Consumers,  June  2021. 
https://op.europa.eu/en/publication-detail/-/publication/1a695500-9e31-11ed-b508-01aa75ed71a1 

85 European Commission, Commission Staff Working Document – Impact Assessment Accompanying the Proposal 
for a Regulation of the European Parliament and of the Council on General Product Safety, SWD(2021) 169 
final, Brussels, 30 June 2021. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52021SC0169 

44 

 
 
 
implementation. As focus group participants, comprising representatives from BEUC, ECCs, 
DG JUST, Member State enforcement authorities, and legal experts, emphasised, the growing 
complexity and cross-border nature of markets, especially in e-commerce, has made EU-level 
infringements  increasingly  frequent.  In  this  regard,  EU-wide  action  was  deemed  more 
appropriate  than  national  responses  alone.  Annual  coordinated  actions  by  CPC  authorities 
targeting specific sectors proved especially relevant in addressing these widespread breaches. 
Further, improvements to the mutual assistance mechanism and the development of common 
enforcement  guidelines  strengthened  cross-border  enforcement  capacity.  The  ECCs  also 
remained highly relevant, providing frontline support to consumers involved in cross-border 
transactions  and  contributing  to  policy  alignment  through  their  role  in  stakeholder 
consultations. 

Stakeholder  engagement  and  civil  society  participation  were  also  important  aspects  of  the 
Programme’s coherence. However, as noted by the EESC, there is a need to further simplify 
procedures  to  enhance  the  participation  of  civil  society  actors,  improve  transparency  in 
communication,  and  ensure  consultations  are  genuine  opportunities  for  input86.  Feedback 
received during the Call for Evidence in 2023 further underlined the Programme’s importance 
to a wide range of stakeholders. Several respondents, including consumer organisations and 
national  authorities,  reiterated  the  relevance  of  EU-level  funding  for  maintaining  robust 
consumer protection systems and enabling knowledge-sharing. Feedback also supported better 
integration  of  consumer  needs  into  digital  and  green  policies  and  advocated  for  targeted 
measures to reach vulnerable groups more effectively. Respondents called for strengthening 
tools like Safety Gate/RAPEX, increasing transparency in ADR and ODR mechanisms, and 
improving enforcement capacity at Member State level, all aligning with the objectives and 
achievements of the Programme. 

4.6 Further evaluation criteria 
Utility: The evidence supports the continued usefulness  of the Programme’s objectives and 
actions, across all four objectives. In particular, the Programme adapted to emerging challenges 
faced by consumers in the context of digitalisation and globalisation. It successfully addressed 
product safety concerns, benefiting vulnerable groups, including children. Tools such as Safety 
Gate/RAPEX and CASPs strengthened market surveillance, contributed to improve the safety 
of products placed on the market. While information sharing, awareness-raising campaigns, 
and educational initiatives remained essential, they were often seen as less useful for consumer 
groups due to how they were designed and implemented. Nevertheless, the growing demand 
for  cross-border  dispute  resolution  and  for  enhanced  cooperation  among  enforcement 
authorities  underlines  the  ongoing  utility  of  the  Programme,  especially  in  the  context  of  e-
commerce  and AI-related safety  concerns. These are increasingly  being  addressed  87revised 
legislation￼  and  initiatives  funded  under  the  Single  Market  Programme.  The  utility  of  the 
cooperation networks was evident, for example, in the activities of the CPC and ECC networks. 
Overall,  the  Programme  was  largely  useful,  with  room  for  improvement  in  addressing 
stakeholder concerns and better responding to consumer needs. 

86  European  Economic  and  Social  Committee  (EESC).  (2024).  Final  evaluation  of  the  Consumer  Programme 

(2014–2020). INT/1053-EESC-2024. 

87 Such as the new General Product Safety Regulation (GPSR) (Regulation (EU) 2023/988), discussed further in 

the case study on e-commerce in Annex VI. 

45 

 
 
 
Complementarity: The Programme was, to a great extent, complementary to other EU and 
national policies and interventions. Funded actions, such as Safety Gate/RAPEX, BEUC, CPC-
Network  and  ECC-Net  are  widely  recognised  to  be  valuable  and  complement  national 
measures.  Collaboration  with  consumer  associations  played  a  crucial  role  in  enforcing 
consumer protection rules at  both  EU and national  levels,  complementing  the efforts of the 
Programme by providing valuable insights and advocacy. Secondly, the Rapid Alert System 
aided  national  authorities  in  implementing  consumer  protection  regulations  by  providing 
timely information on dangerous products. Thirdly, EU-level risk assessments and scientific 
opinions informed the development of consumer policies at the Member State level. Finally, 
the  Programme's  actions  contributed  to  broader  policy  objectives  such  as  the  Europe  2020 
Strategy and Sustainable Development Goals, aligning with overarching policy agendas and 
enhancing its impact on societal and environmental goals. 

Coordination:  To  assess  coordination,  the  evaluation  examined  the  extent  to  which  the 
Programme's  actions  were  strategically  organised  to  maximize  their  collective  impact, 
including by mobilising resources and harmonising measures. This was analysed in relation to 
two  specific  objectives:  improving  consumer  services  safety  and  enhancing  enforcement 
coordination. Thanks to its centralised coordination and support mechanisms, the Programme 
enabled Member States to collaborate more effectively, share best practices and pool resources 
to achieve goals. The judgment criteria included the coordination of market surveillance and 
enforcement actions on product safety, as well as support provided to bodies recognised by 
Union  legislation  for  the  coordination  of  enforcement  actions  between  Member  States.  By 
pooling  resources  through  platforms  like  Rapid  Alert  System,  the  Programme  ensured  a 
comprehensive  approach  to  identifying  and  addressing  dangerous  products.  Harmonisation 
efforts,  such  as  EU-wide  follow-ups  and  coordinated  activities,  like  joint  sweeps  aimed  to 
establish consistent consumer protection standards and enforcement practices.  

Equity: was assessed by examining how equitably the Programme’s effects were distributed 
across regions, stakeholders, and vulnerable consumers. The evaluation revealed disparities in 
Member State participation, partly due to language barriers. Efforts to improve accessibility, 
such  as  translating  Safety  Gate/RAPEX  alerts  into  all  EU  languages  (since  2018)  and 
simplifying  user  interfaces,  helped  mitigate  this.  Despite  continued  regional  differences, 
particularly in consumer conditions across eastern and southern EU countries, progress toward 
narrowing the gap was  observed. The Consumer Markets  Scoreboard showed that financial 
status influenced consumer experiences, with financially struggling individuals reporting lower 
satisfaction  and  less  likelihood  to  seek  redress.  BEUC  addressed  some  vulnerability  issues, 
such  as  energy  poverty,  payment  fraud,  and  vulnerable  borrowers,  but  broader  attention  to 
vulnerable groups was limited. Children were primarily mentioned in  the context of unsafe 
toys,  and  one  cosmetics  risk  assessment  lacked  adequate  consideration  of  vulnerable  users. 
Overall, Programme outputs addressing vulnerable consumers were limited and concentrated 
in  2017–2020, mainly  via behavioural  studies.  In a sample of 97 funded projects,  only  five 
explicitly  targeted  vulnerable  groups.  These  findings  partially  align  with  EESC  concerns, 
which called for earlier and more systematic integration of vulnerable consumer needs across 
all Programme objectives88. 

88  European  Economic  and  Social  Committee  (EESC).  (2024).  Final  evaluation  of  the  Consumer  Programme 

(2014–2020). INT/1053-EESC-2024. 

46 

 
 
 
Sustainability: The sustainability of the effects of interventions showed a mixed picture, but 
on the whole most funded actions will have long lasting results. Regulatory measures supported 
by the Programme have resulted in enduring structural changes. Ongoing alert services, such 
as the Rapid Alert System, ensure continuous monitoring of product safety. Risk assessments 
and scientific opinions remain relevant until updated due to new discoveries. Platforms like the 
ODR platform provided a foundation for sustained consumer protection in online transactions. 
Although a decision to discontinue the ODR platform has been made, useful elements of it such 
as  the  database  of  ADR  bodies  will  continue  to  be  used.  The  impact  of  the  Programme  on 
international systems was not well documented in the literature reviewed.  

Acceptability was assessed based on how well the Programme’s interventions aligned with 
consumer  needs,  higher  alignment  typically  signals  greater  acceptability.  The  Programme 
demonstrated strong alignment, as seen in BEUC’s advocacy during Dieselgate, enforcement 
actions addressing penalty gaps, and the emphasis on product safety and authority cooperation. 
Internally,  actions  were  implemented  with  a  high  degree  of  coherence.  The  evaluation  also 
examined the Programme’s role in ensuring a consistent level of consumer protection across 
the EU and EEA. Despite some coordination challenges for EU-level associations and varying 
national collective redress procedures, mechanisms like Safety Gate/RAPEX and CPC joint 
actions significantly contributed to harmonised enforcement and responses. To identify shifts 
in  perception,  historical  and  current  stakeholder  and  public  views  were  compared.  Public 
perception was influenced by several factors, including high-profile product safety incidents 
such as the Samsung Galaxy Note 7 overheating issue. 

5.  WHAT ARE THE CONCLUSIONS AND LESSONS LEARNED? 

5.1 Conclusions 
The  ex-post  evaluation  demonstrated  that  the  Programme  has  been  broadly  effective  with 
regard to its main objective and the four specific objectives, efficient and had EU added value. 
It  was  coherent  and  relevant.  However,  while  the  available  indicators  provide  evidence  of 
outputs  and  immediate  results,  their  fitness  for  tracking  long-term  impact  remains  limited. 
Several indicators remained output-focused, and few were linked to baseline or target values, 
making  it  difficult  to  measure  changes  in  consumer  detriment  or  business  compliance.  The 
evaluation  relied  on  triangulated  qualitative  data,  interviews,  focus  groups,  stakeholder 
surveys, to fill these gaps, but acknowledged the limitations of these sources, particularly the 
non-representative  nature  of  the  57-survey  responses  and  the  likely  selective  memory  bias. 
Where observational data (e.g. Scoreboard trust metrics, market outcomes) were available, they 
were used to reinforce the conclusions, but cannot be interpreted as directly attributable effects 
due to the absence of a counterfactual. 
Regarding effectiveness, the evaluation demonstrated that the Programme has been broadly 
effective  in  achieving  its  objectives.  Under  Objective  I,  Safety  Gate/RAPEX  significantly 
improved cross-border product safety coordination, reduced disparities in market surveillance, 
and  contributed  to  greater  consumer  confidence  in  cross-border  shopping.  The  Coordinated 
Activities  on  the  Safety  of  Products  (CASP)  benefited  national  authorities,  businesses,  and 
consumer  organisations—particularly  in  recall  effectiveness  and  informing  legislation. 
However, challenges remain due to unequal enforcement resources among Member States and 
ongoing  difficulties  integrating  scientific  advice  into  regulatory  processes.  Maintaining 
consistent standards and coordination across Member States continues to require attention. 

47 

 
 
Under  Objective  II,  BEUC’s  activities  effectively  coordinated  national  consumer 
organisations  and  ensured  their  input  into  EU  policymaking  on  digital,  environmental,  and 
financial issues, including those affecting vulnerable consumers. In contrast, other consumer 
awareness and education initiatives, despite achieving outreach metrics, had limited long-term 
impact on consumer knowledge and trust, as reflected in Consumer Scoreboard data. Structural 
challenges, including low integration into national curricula and declining NGO trust, hindered 
broader effectiveness. Programmes like Consumer Law Ready and Consumer PRO performed 
strongly, meeting targets and adapting well to online delivery during COVID-19, with reported 
improvements  in  knowledge  and  behaviour.  However,  Consumer  Champion  and  Consumer 
Classroom underperformed due to low engagement, lack of localisation, and weak alignment 
with national systems.  

Under Objective III, the Programme was moderately effective in supporting consumer rights 
and access to redress. Behavioural and market studies were a key strength, informing major 
policy  initiatives  (e.g.  Consumer  Credit  Directive,  UCPD)  and  cited  as  good  practice 
internationally.  However,  their  direct  enforcement  impact  was  limited.  The  ODR  platform 
reached  visibility  and  usage  targets,  but  its  resolution  rate  remained  extremely  low  (~1%), 
mainly  due to limited trader participation.  While  ADR structures benefited from  grants  and 
training,  uptake  and  awareness  remained  uneven  across  the  EU,  and  key  performance 
indicators were not achieved. Progress was made in strengthening redress infrastructure, but 
systemic and legal limitations undermined its full potential.  

Under Objective IV, the Programme effectively supported cross-border enforcement through 
the  CPC  Network  and  ECC-Net,  though  with  mixed  results.  ECCs  consistently  exceeded 
targets for consumer contacts and website visits, proving effective especially in countries with 
fewer  resources.  Conversely,  CPC  Network  performance  indicators  showed  declining 
effectiveness,  notably  in  the  timeliness  and  number  of  enforcement  actions.  Nonetheless, 
stakeholder feedback strongly supported the added value of EU-level coordination, the CPCS 
IT platform, and joint enforcement actions—particularly for tackling online infringements. The 
Programme helped maintain a minimum level of enforcement capacity across Member States, 
but uneven national commitment and resourcing continued to constrain outcomes. 

With regards to efficiency, under Objective I, the Programme demonstrated high efficiency 
by pooling resources and coordinating market surveillance activities. CASP projects were cost-
effective,  enabling  joint  product  testing  at  significantly  lower  average  costs  compared  to 
national  testing.  The  integration  of  Safety  Gate/RAPEX  with  ICSMS  further  enhanced 
efficiency  by  improving  information  flows  and  avoiding  duplication.  However,  efficiency 
varied across Member States due to differences in administrative capacity and levels of national 
funding.  

Under Objective II, efficiency outcomes were mixed. Initiatives like Consumer Law Ready 
and Consumer PRO achieved strong economies of scale and consistent training quality across 
Member States, making effective use of EU coordination. In contrast, digital outreach tools 
such as Consumer Champion and Consumer Classroom showed limited efficiency due to low 
uptake  and  weak  sustainability,  despite  considerable  resource  inputs.  The  BEUC  operating 

48 

 
 
 
 
 
 
 
grant  was  generally  considered  efficient  given  its  broad  coordination  role,  but  limited 
availability of detailed cost and output data prevented a full assessment.  

Under Objective III, efficiency was  undermined by the low cost-effectiveness  of the ODR 
platform, which incurred substantial investment but resolved only a small number of disputes. 
By  contrast,  ADR  mechanisms—when  used—proved  more  cost-efficient  for  consumers, 
traders, and Member States. Grants supporting the digitalisation of ADR and the exchange of 
best practices improved efficiency at the organisational level. However, the full potential of 
these grants was not realised, as funding uptake was limited and the Programme was unable to 
disburse its full allocations.  

Under  Objective  IV,  ECCs  showed  high  efficiency  by  consistently  meeting  increasing 
consumer demand without significant increases in EU funding. Their collaborative structure 
enabled more resourced centres to assist others, boosting overall network performance. CPCS 
activities  were  more  variable:  while  joint  enforcement  actions  and  training  helped  reduce 
fragmentation, several performance indicators declined or stagnated. This was partly due to 
uneven  national  investment  and  administrative  burdens.  Stakeholders  highlighted  the 
importance  of  Commission  coordination,  which  was  viewed  as  a  necessary  and  efficient 
enabler, though returns on investment varied by Member State. 

On internal  coherence,  the Programme’s four objectives  were broadly  complementary and 
mutually reinforcing. Actions funded under different objectives (e.g. behavioural studies under 
Objective III informing campaigns under Objective II, or ADR capacity-building supporting 
ECC  work  under  Objective  IV)  demonstrated  functional  synergy.  Internal  coherence  was 
evident  in  the  alignment  between  educational  initiatives,  enforcement  coordination,  and 
consumer  information.  However,  some  gaps  persisted,  particularly  in  the  underexploited 
collaboration between ECCs and the CPC Network, and the limited integration of ECCs with 
ADR entities in sharing practices and feedback mechanisms.  

On  external  coherence,  the  Programme  was  well  aligned  with  EU  consumer  law,  notably 
Article 169 TFEU and Article 38 of the Charter of Fundamental Rights, which require a high 
level of consumer protection. It supported implementation of the 2012 Consumer Agenda and 
ensured coherence with EU strategies such as the Digital Single Market, the Green Deal, and 
sustainability  policy.  Its  tools  and  funding  filled  important  implementation  gaps  in  EU 
consumer acquis, and complemented other EU programmes, such as the Rights, Equality and 
Citizenship Programme and the LIFE Programme, without duplication. 

With regards to EU added value, the Programme demonstrably enabled actions that Member 
States  or  stakeholders  could  not  have  undertaken  independently.  This  includes  coordinated 
enforcement  actions  through  CPC  and  CASP,  cross-border  complaint  handling  via  ECCs, 
supranational  behavioural  research,  and  harmonised  training  platforms  like  Consumer  Law 
Ready.  Interviewees  and focus group participants confirmed that EU-level  intervention was 
essential for scale, consistency, and legitimacy, particularly in cross-border contexts, digital 
markets, and areas where national capacity was weak. 

On  relevance,  the  Programme  remained  well  aligned  with  consumer  needs  throughout  the 
2014–2020 period, adapting  to  key structural  shifts  such as digitalisation, the rise of online 

49 

 
 
 
 
platforms, and the COVID-19 pandemic. Its focus areas, product safety, redress, information, 
and  enforcement,  addressed  persistent  and  emerging  risks.  While  the  needs  of  vulnerable 
consumers  were  not  always  sufficiently  targeted,  the  Programme  overall  retained  its  policy 
relevance,  as  confirmed  by  both  stakeholder  feedback  and  independent  evidence  (e.g. 
Scoreboards, complaint data, Safety Gate/RAPEX alerts). The continued inclusion of the same 
objectives in the SMP 2021–2027 reflects this enduring alignment. 

5.2 Lessons learned 
Throughout the evaluation several areas for improvement have been identified: 

•  Ensure consistent data collection and record keeping, so as to enable evaluations 
of  funding  programmes:  a  consistent,  systematic,  comprehensive  and  accurate 
method  for  recording  documentation,  including  a  list  of  all  funded  projects  and  a 
comprehensive set of project data records required for evaluation shall be established. 
Data consistency across all funded activities, including data on outputs, and results shall 
be improved. 

•  Further develop indicators to better monitor impact: Develop outcome and impact 
indicators that focus on the quality of deliverables and achieved results. Measurement 
should expand beyond the simple numerical indicators and should also focus to capture 
quality, e.g. the quality of BEUC’s interactions with policy makers in terms of influence 
they have had, rather than just the number of meetings or presentations. For ECCs and 
the CPC network, for example indicators should focus on the nature and extent of the 
actions taken or results for consumers. 

•  Streamline campaigns, and information and education provision: Strengthen the 
role  of  BEUC  and  national  consumer  organisations  in  information  and  education 
activities to enhance the impact and reach of consumer protection initiatives across the 
EU. Limit EU communication campaigns to key topics targeting consumer awareness. 
Enhance  consumer  education  through  diversified  communication  channels  and 
strengthen school programmes to include consumer-related information.  

•  Maximise  the  use  of  behavioural  studies  to  support  policy-making  and 
enforcement:  Continue  conducting  studies  supporting  policy-making  and  initiate 
studies to support CPC authorities. Conduct both large and smaller studies to ensure 
more  flexibility  and  keep  them  supra-national  to  address  common  concerns  across 
Member  States.  Increase  access  to  data  supporting  policy-making,  particularly  for 
academic scholars and consumer organisations. 

•  Strengthen co-operation and communication between national actors to further 
build capacity: Promote networking and collaboration and creating further synergies 
by  joint  planning  of  and  outreach  about  activities  and  encourage  greater  sharing  of 
knowledge, data and expertise, as well as tools and approaches. Revise how impacts of 
joint working are captured. Continue with joint training initiatives to build capacities at 
national level.  

•  Strengthen the Safety Gate/RAPEX: Continue ensuring that Safety Gate reflects the 
new General Product Safety Regulation by, amongst others, enabling direct consumer 
reporting of unsafe products through the Consumer Safety Gateway, facilitating closer 
interaction  between  online  marketplaces  and  national  authorities  through  the  Safety 
Business Gateway, and improved interoperability between systems like the Information 
and  Communication  System  on  Market  Surveillance  (ICSMS),  Safety  Gate,  etc. 

50 

 
 
Continue providing opportunities for common risk assessments through CASP or other 
formats,  and  keep  the  CASP  framework  agile  and  responsive  to  emerging  risks  and 
unexpected situations such as COVID-19. 

•  Streamline support for and obligations to participate in ADRs: Further simplify the 
funding application process ADR bodies, especially for smaller organisations, to reduce 
administrative burden and improve funding access, and closely monitor the uptake of 
the programme’s funding for ADR. Strengthen collaboration among Member States to 
improve the fragmented ADR landscape across Europe and encourage sector-specific 
networks of ADR bodies to collaborate, helping to alleviate administrative challenges 
through shared resources, exchange of best practices and enhance information flow.  
•  Strengthen enforcement: Increase utilisation of the mutual assistance mechanism and 
improve handling times for enforcement requests within the CPC network. Expand and 
upgrade IT tools to enhance coordination and response times across Member States. 
Continue investing in e-enforcement training to equip authorities for the challenges of 
digital marketplaces. Strengthen cross-border enforcement efforts through joint actions 
and peer-to-peer meetings. Foster increased cooperation between the CPC Network and 
ECC Net. Also in the area of product safety, make use of all enforcement options that 
the GPSR provides for, including for example sweeps. 

51