You will find attached the Position Paper of Ecommerce Europe. We overall welcome the publication of the European Commission’s Proposal for a Regulation on fairness and transparency in online platform trading. In particular, the European e-commerce association appreciates and supports the soft-touch and principle-based approach proposed by the Commission. Online platforms, such as e-commerce marketplaces, are engines of growth and Ecommerce Europe wants to stress that this Regulation should struck the right balance between their interests and the interests of online merchants, especially SMEs that sell via marketplaces. Well balanced also in redress rights which, in the view of Ecommerce Europe, are best served by a transparent complaints-handling completed by a fair mediation system, however not by the proposed representative court action which in our view lacks the balance between collective redress and individual redress. This position paper analyzes in detail the proposed Regulation and gives specific recommendations on how to improve it and achieve this fair balance. We look forward to working together with all EU policymakers on this important legislative file and we remain available for any questions or remarks.
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