1. Closing Remarks and Next Steps
Remko Bos
Brussels, 2 October 2017

2. Challenges of Bundled Products (1/2)
Contractual Issues
Distinguish between Bundled Contracts (one contract, 2 products) and Added Contracts (with different companies)
Multi company contracts No single point of contact
Unclear contract conditions  Overlapping/contradicting contract conditions per service e.g. discount applied to only one of the services or different switching periods
(Unfair) commercial practices
Harder for consumers to compare offers
Complex comparison  difficult to compare bundles (prices, quality etc.)
Many online price comparison tools don’t (yet) compare bundled offers and contractual conditions
Lessons from airline business  trend to unbundle – only possible to compare base fare but not the Additional Services (e.g. luggage sizes differ per company)
Suppliers have an incentive not to make single product elements available
Complex billing information
Extra issues e.g. data management and privacy
29/08/2018

3. Challenges of Bundled Products (2/2)
Competition Issues
Replicability
Market consolidation
Price opacity
Switching is sticky – consumer lock in and market failure
Complaints
Complex billing information
To whom should consumers complain?  avoid regulator and ombudsman ping-pong need a (database/map of whom to contact – possible single point of contact?)
How to classify bundled product complaints e.g. telecoms, energy, insurance
Sanctions – can your regulator fine? Consistency in enforcing consumers rights
29/08/2018

4. Bundled Product Opportunities
Bundled Products as the new business model
New packages of bundled services  Trend that is here to stay
Telecoms  churn or switching out of bundled products is low – LOCK IN
Airlines  trend to unbundle but suppliers are not transparent on price
Energy  risk of essential service (energy supply) being affected by additional products
Opportunities for closer cooperation between different regulators
Consumers need easy to understand, easy to compare and consistent information
General consumer legislation as a firm basis  essential element across all sectors
Sector specific rules can compliment but must be consistent with consumer laws. Beware of rules per sector.
Evolution of prices comparison tools  not only price not only comparisons but also suppliers should help consumers to exit contracts and bundles (advice as part of the commodity)
29/08/2018

5. Partnership for Enforcement of European Rights (PEER) – next steps (1/2)
Information and knowledge sharing among different regulators  effective and consistent enforcers
Case Studies (e.g. Portuguese interruption of energy due to non-payment of equipment maintenance services)
Guidelines exist e.g. ERSE (PT) on energy, ACM (NL) on general consumer law
Is there interest to develop TOGETHER guidelines on commercial practices (based on Case Studies or principles) for companies to adhere to due professional diligence on bundled products?
Good cooperation among sectoral regulators exists
PEER website – repository of good resources will be made public
29/08/2018

6. Partnership for Enforcement of European Rights (PEER) – next steps (2/2)
Raising Awareness
EU associations (CEER, BEUC, NEON etc) committed to engaging with others through PEER  increase awareness among our members (e.g. our meetings, conferences e.g. CEER Customers Conference)
Other channels? Reach out to Consumer Protection Authorities, Data Protections Authorities, European Commission to raise consumer awareness (e.g. single point of contact, mandatory information on complaint handling in case of bundled products)
Clarify jurisdiction - set up a database of who is the right regulator/ombudsman/authority to contact if the consumer has a problem with a product/service (European Commission?)
Other PEER events?
“Power of PEER” (online newsletter) to share lessons from our dialogue?
29/08/2018

7. Possible PEER area for future?
Smart metering, data privacy and data protection, and the Internet of Things
Cybersecurity
Enforcement issues concerning unfair commercial practices
Others?

8. Thank you for your participation!