Cmparisn Websites Cntact: Mnique Gyens directrsffice@beuc.eu Ref.: X/2012/065-28/08/2012 BUREAU EUROPÉEN DES UNIONS DE CONSOMMATEURS AISBL DER EUROPÄISCHE VERBRAUCHERVERBAND Rue d Arln 80, B-1040 Brussels Tel. +32 (0)2 743 15 90 Fax +32 (0)2 740 28 02 cnsumers@beuc.eu www.beuc.eu EC register fr interest representatives: identificatin number 9505781573-45
Summary This dcument summarises the requirements that cmparisn websites have t meet as a general rule in rder t adequately respnd t legitimate cnsumer expectatins. They cncern different aspects, such as : Transparency f business mdel Cverage Up-t-datedness Verifiability and reliability Accuracy Independence f the infrmatin prvider Clarity and user-friendliness Accessibility Reprting Supervisin. 2
Cmparisn websites BACKGROUND T take advantage f cmpetitive markets, cnsumers need t be equipped t shp arund in rder t btain the best deal. In this cntext, cmparisn websites ffer a huge ptential fr enhancing cnsumer access t infrmatin and hence cnsumer mbility. Cmparisn websites can therefre be a tl fr mre cmpetitive markets. This dcument prvides fr best practices that BEUC and its member rganisatins cnsider t be key fr cmparisn websites t deliver added-value t cnsumers. Cntext Mre and mre cmparisn websites exist n the internet and they are prmted as assisting cnsumers in their search fr the best ffer, by centralizing the infrmatin available frm different prviders, within a given cuntry r acrss the bard. There are therefre cnsidered t carry the ptential f enhanced cnsumer chice and als encuragement f crss-brder e-cmmerce. Cnsumers ften trust the infrmatin available n the internet and are nt aware that sme f this infrmatin, als that prduced by CW, can be biased fr different reasns. Therefre, in rder t prmte cnsumer trust in CW, it is essential that thse respect specific requirements that are listed belw. It is imprtant t distinguish cmparisn websites frm reviews, where cnsumers indicate their assessment f prducts r services: these web-pages, which are ften trusted by cnsumers, cause a lt f prblems f credibility: their validatin prcess is nt guaranteed, a lt f fake cnsumers participate t the prcess, the uplading f negative cmments is smetimes prevented. These types f shrtcmings lead t cnsumer detriment and put int questin the credibility f the mre serius websites. Therefre it is essential t als regulate and mnitr the respect f rules f cnsumer infrmatin, absence f misleading messages and unfair marketing practices fr thse web-pages. REQUIREMENTS FOR CONSUMER EMPOWERING CW Transparency n business mdel As already indicated, it is essential that the CW indicates in a prminent and easily understandable way t the cnsumer its different characteristics. This will allw cnsumers t assess the impartiality f the advice. the wnership f the CW (r sharehlders) the financing mdel (wh pays fr what service) Frequency f updating Gegraphic cverage Methdlgy (ranking factrs, surce f infrmatin.) 3
Cverage f sectr (all prviders, percentage f sectr cncerned, nly thse wh participate in the scheme, why sme prviders d nt participate in the scheme ) Cverage The mre exhaustive the website, in terms f prviders/prducts f the categry searched fr by the cnsumer, the mre extensive the cnsumer chice. Hwever, in sme sectrs, it is essential that this exhaustivity is cmbined with search and ranking factrs that will make it pssible fr the cnsumer t fcus n a specific segment that crrespnds t his expectatins. Hwever, it is imprtant nt t verfcus n the quantity f infrmatin, but t cncentrate n the infrmatin that meets the cnsumer s real needs and expectatins and its suitability shuld be gauged in line with specific purpse, cntent, presentatin and cntext. The ntin f cverage als extends t the gegraphical scpe f the CW: fr it t deliver ptential crss-brder benefits t cnsumers, it wuld be interesting t include ffers frm different cuntries. While it wuld be gd t highlight gd deals frm ther cuntries, CW can hwever nt be expected t prvide fr exhaustive listings in this cntext. Up-t-datedness The rapidity f internet implies that the cnsumer expects all infrmatin n line t be updated. It is therefre essential that the cnsumer is prminently infrmed abut frequency f updating as well as f last update Verifiability The infrmatin prvided by the CW must be easily verifiable by the cnsumer, i.e., via a link t the prvider cncerned, every time it is pssible. Accuracy A majr ranking factr being the price, it is essential t include as much as pssible the final price (charges, fees, delivery csts, taxes). Partitined pricing shuld be allwed nly in cases where it is nt pssible t prvide a general glbal price fr all searches. The key cncept in this respect is the cmparability : even if it is true that certain csts vary significantly depending n factrs such as the place f residence f the cnsumer, the delay fr delivery etc, there shuld always be a cmmn grund fr cmparisn (eg inclusin f the cheapest delivery cst). This f curse depends n the prduct sectr cncerned : in sme sectrs, like airline tickets, the final price shuld be displayed, while in sme ther sectrs, csts can vary significantly depending n where the cnsumer resides r n the delivery deadline. Als, if the default ranking takes place accrding t anther factr than the price (e.g. payment by prvider t be ranked high), this must be prminently displayed t the cnsumer. Exhaustivity A well functining CW must clearly state fr each ffer the main terms f subscriptin, fees and special clauses, and indicate clearly if they are unusual r burdensme. This infrmatin shuld be presented in a cmparable frmat fr all 4
ffers, t make it easy fr cnsumers t have an verview. 1 This element is key, because if t much emphasis is put n prices, cmpanies culd be tempted t lwer prices in rder t lk mre attractive n the website), by wrsening the ther terms f subscriptin, which the cnsumer will becme aware f nly afterwards. Als, price infrmatin shuld include discunts, as well as infrmatin n the terminatin date and cnditins fr the discunt. Independence The prvider f the cmparisn website must be independent frm the individual cmpanies that are surveyed n the site, in rder t prvide fr a nndiscriminatry verview f the market. Reliability Cnsumers must be able t trust the infrmatin that is prvided. The CW must in n way mislead the cnsumer as t the accuracy f the infrmatin displayed. Clarity and user-friendliness Fundamentally, the infrmatin prvided by the CW must be precise, relevant, understandable and readable. Difficult legal and technical cncepts must be avided wherever pssible. The CW must be displayed in a way that infrms the cnsumer clearly abut the main features f the CW and the cmparisn it prvides. In this respect, it is essential that user-interfaces be built in a user-friendly way, and in ways that actually seem appealing fr users and facilitate nn-experienced users t interact with the website. Accessible als t vulnerable cnsumers CW must use technical features that enable visually impaired r ther disadvantaged cnsumers t use the device, in line with the WCAG standards (web cntent accessibility guidelines). Als, it is imprtant t make cmparative infrmatin available fr cnsumers that d nt have access t the internet fr free r at a minimal cst (regular printed reprts, printed versin sent n request, by telephne, etc.) Reprting When a cmparisn has taken place and is limited in time, a reprt shuld be made available t the different prviders and t market authrities in rder t check methdlgy and market cverage. When a cmparisn is unlimited in time, regular reprts shuld be made available, at least n a mnthly basis, n methdlgy and market cverage. Supervisin Supervisry authrities, either in charge f general cnsumer prtectin plicy r mre sectr specific, such as in telecms r in the energy sectr, shuld practively mnitr the respect f these cnditins in rder t enhance cnsumer trust in the infrmatin prvided by CW. 1 A red triangle is used in the Danish Electricity Price Prtal t indicate that an usual term f subscriptin is part f the ffer. The cnsumer can check by clicking the symbl, what this term is. 5