From the start, the Consumer rights directive has been presented as a magic pill to solve the remaining issues outstanding in the EU to secure both high level consumer protection and finalise the internal market for an optimal exchange of goods and services. The maximum harmonisation option along with the concrete proposals inside the original draft came far from addressing these issues. Many member States' level of protection would have been lowered or at best, locked for the next years with an impossibility to legislate and provide higher protection if need be.

Firstly, it needs to be underlined that many online goods and services are provided across Europe, despite the lack of consistency in consumer protection, simply because the providers drafted a single high level consumer rights protection policy complying with all the existing legislations in the EU.

Furthermore, the directive failed to identify that the costs associated with translation, consumer service in relevant languages, delivery costs as well as lack of clarity of providers' websites with regards to cross-border trade would still present obstacles for the EU exchange of goods and services and would thus not boost consumer confidence or solve all problems for cross-border trade of goods and services.

In this light, COFACE insists on uphold the principle of targeted harmonisation so as to provide benefits for the consumers where need be without presenting an obstacle to the provision of future improvements to consumer protection policy developments initiated by member States or the EU institutions.