Prepared by ETNO working groups of company representatives, these require the consensus approval by all ETNO Full Members.
Also prepared by working groups, Reflection Documents carry the approval of at least two-thirds of ETNO’s membership. Such a document does not necessarily represent the final position of ETNO on a topic, but provides a solid indication of the majority view among its members. Many ETNO papers take this form.
This is not a position paper but a document offering a common but unofficial viewpoint, agreed by consensus within an ETNO working group and endorsed by the association’s Executive Board. Expert Contributions differ from Common Positions and Reflection Documents in that they are not approved by ETNO’s membership at large. But they often address technical or organisational questions at the expert level and enable ETNO to comment quickly on a given subject when short deadlines are in play.
Issued on an occasional basis, these documents reflect common views shared by ETNO and other industry and trade organisations regarding either specific topics or horizontal issues.
Latest position papers
ETNO and GSMA joint position paper on Article 13 of the proposed Directive on Copyright in the Digital Single Market
The core aim of Article 13 of the proposed Directive on Copyright in the Digital Single Market is to consider the legal relationship between content rights-holders and a new class of information society service provider termed a ‘online content sharing service provider’ (“OCSSP”) that stores and gives public access to copyright works such as music/audiovisual content. Article 13 represents a focussed sector-specific approach to addressing the so-called ‘value gap’ by requiring that OCSSPs obtain necessary authorisations from relevant rights-holders.
ETNO and GSMA joint position paper on the proposal for a Directive on Better Enforcement and Modernisation of EU consumer Protection Rules
ETNO and the GSMA welcome the objectives of the proposals on “A New Deal for Consumers”, which aim at updating consumer protection standards and improving enforcement. To effectively reach these, objectives several crucial adjustments are required, addressing only clearly identified problems in a targeted way and based on the principle of proportionality. More efforts should be focused on enforcing existing rules, rather than creating new ones which might be rendered ineffective. While the level of legal harmonisation should increase, Member States need to keep some flexibility to specify EU level provisions.
ETNO and GSMA joint position paper on the proposal for a Directive on Representative Actions for the Protection of the Collective Interests of the Consumers
ETNO and the GSMA welcome the objective to improve law enforcement and strengthening consumer protection across the EU, irrespective of the location of size of an undertaking. This also requires Member States to provide sufficient resources, which is unfortunately not addressed in this proposal. Rules should be fully harmonised, providing Member States some flexibility to specify EU level provisions. As general remark, we believe that the new rules should take into account sector specific law to make sure they are aligned and do not create too much burden on actors that are already strictly regulated.