think digital
European Telecommunications Network Operators' Association



RD429 - ETNO Position on Draft Directives on certain aspects concerning contract for the online and other distance sales of goods and of digital content

Read ETNO's full position here.

ETNO welcomes the declared aim of the European Commission’s initiative to provide more harmonised, effective and future proof consumer protection rules for online services. However, this target can only be reached based on a comprehensive approach for the digital market. Accordingly, the legislation “on certain aspects concerning contract for the online and other distance sales of goods” (tangible goods directive) and particularly “on certain aspects concerning contracts for the supply of digital content” (digital content directive) needs to consider parallel legislative processes. Moreover, this legislation needs to consider as well, the integration of established consumer protection standards which refer to “better access for consumers and businesses to online goods and services across Europe” (Commission's Communication on a Digital Single Market, 2015).

In addition to supplementing the Consumers Rights Directive 2011/83/EU, the legislative procedure should also ensure alignment with existing sector-specific rules such as the regulatory framework for electronic communications networks and services1, currently under review.

Although supporting the high level objectives of the European Commission’s proposed draft directives, ETNO fears significant shortcomings and uncertainties. If not substantially revised, the new legislative instruments will create greater legal uncertainty both for consumers and service providers.

Read ETNO's position here.


1. A wide range of consumer protection rules are particularly included in the Universal Service Directive 2002/22/EC amended through Directive 2009/136/EC

Members & Observers - View companies map

  • A1 Telekom Austria Group
  • Albtelecom
  • Altice Portugal
  • BH Telecom
  • BT
  • CYTA (Cyprus Telecommunications Authority)
  • Deutsche Telekom AG
  • Eir
  • Elisa Communications Corporation
  • GO Plc (Malta)
  • Hrvatski Telekom
  • Koninklijke KPN
  • Magyar Telekom
  • Makedonski Telekom
  • Orange
  • Orange Polska
  • OTE
  • POST Group
  • Proximus
  • Síminn (Iceland Telecom Ltd.)
  • Slovak Telekom
  • Swisscom
  • TDC
  • TDF
  • Telecom Italia
  • Telefónica
  • Telekom Slovenije
  • Telenor
  • Telia Company
  • Vivacom
  • AT&T
  • Cisco
  • Ericsson
  • Huawei
  • Nokia
  • Prysmian Group
  • Qualcomm Europe Inc.
  • Verizon

ETNO aisbl - Boulevard du Régent 43-44 - 1000 Brussels - Belgium

Phone: +32(0) 2 219 32 42 -