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Francisco Pinto Balsemão
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Proposal for a Directive on Services in the Internal Market (COM 2004/2)


Dear Sir/Madam,
The undersigned organisations welcome the Commission proposal for a directive on Services in the Internal Market (2004/2).

In our opinion, the text released by the Commission forms a strong foundation on which to build a coherent legislative framework for services in the internal market of the European Union.

A key element of any proposal which aims at the completion of the internal market must be the Country of Origin principle. The Services directive proposal benefits from a strong commitment to this principle. The inclusion of a Country of Origin principle in any revision of the proposal is of the utmost importance.

Guarantees on freedom to provide services cross-frontier should not be restricted on the basis of claims that consumer protection will be compromised by the inclusion of the Country of Origin principle in this directive. EU-level legislation on consumer protection, including the Unfair Commercial Practices directive and Enforcement regulation provides consumers with adequate protection in this area.

In this paper we will focus on the wider perspective of the proposal and the overall benefits it will bring to European business and consumers. We will detail any fine-tuning we feel may be necessary in a separate position.

This directive will be of benefit to European business and consumers because:

  • Its adoption will ensure that there is an effective way of removing red tape which prevents business from offering services across borders and consumers from taking up those services;
  • The inclusion of a country of origin clause within the directive gives legal certainty to business and is likely to encourage more traders to offer services throughout the EU. For any business likely to cross borders what is essential is legal certainty - legal certainty that whatever we distribute will not fall foul of the law wherever it is received and is not subject to the laws of the 25 different legal systems in the EU. This assurance of legal certainty will in turn be of benefit to consumers because they will have a wider choice of services and service providers in many areas;
  • The adoption of this directive will result in significant progress on the path towards a truly integrated single market in both goods and services;
  • The establishment of a proper internal market for services will mean significant progress towards the achievement of the goals the Commission has set for itself recently in its review of the Lisbon Agenda.

It should be borne in mind at this stage that more important than the detail of separate articles is the overall effect this directive will have. A completed internal market in services, which works effectively for both business and consumer alike is the main aim of the proposal. We feel the current text under discussion goes a long way towards achieving that aim.

At the same time we are aware of the need (as with all proposals in their early stages) to investigate ways of making this directive as coherent as possible. We look forward to discussing how this might be achieved with all of the Institutions in the coming months.

Yours faithfully,


Andrew Brown, Manfred Parteina, Directors, Advertising Information Group
Dominic Lyle, Director General, European Association of Communications Agencies (EACA)
Aad Weening, Secretary General, European Distance Selling Trade Association (EMOTA)
Angela Mills Wade, Executive Director, European Publishers' Council (EPC)
Simon Litton, Secretary General, Interactive Advertising Bureau, Europe (IAB Europe)
Alasdair Tempest, Director General, Federation of European Direct and Interactive Marketing (FEDMA)
David Mahon, Director, European Federation of Magazine Publishers (FAEP)
Marina Palomba, Legal Director, Institute of Practitioners in Marketing (IPA)
Peter Kerr, Chairman, Institute of Sales Promotion Limited (ISP)
Louis Armstrong, Chief Executive, Royal Institution of Chartered Surveyors (RICS)
Stephan Loerke, Managing Director, World Federation of Advertisers (WFA)


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