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Position Papers Archive

 

Commercial communication (including restrictions on advertising)

EPC response to the public consultation on the future of the Internal Market Communication from the Commission (also in PDF) (July 2006)

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

Policy Statement - Freedom of Commercial Communication. Prepared by the ICC Commission on Marketing and Advertising (PDF file) (download as Word document)

Letter to President Prodi and Secretary General O'Sullivan concerning the regulations on advertising in the food and beverage industry

EPC slams Commission for media censorship proposal (July 2003)

Sales Promotion letter to MEPs (August 2002)

Tobacco - joint industry position (08 April 2023)

Commission consultation on "An Internal Market Strategy for Services" - contribution from the European Publishers' Council (01 June 2023)

Finding new ways to regulate advertising and other forms of commercial communications in the age of on-line communications

Briefing for members of the European Parliament on the draft directive to ban all tobacco advertising and sponsorship

Tobacco advertising

Tobacco advertising ban -  letter to Byrne (10 October 2023)

 

Competition policy

EPC response to the public consultation on the future of the Internal Market Communication from the Commission (also in PDF) (July 2006)

Joint call for postal liberalisation (published in the European Voice): "Call on the European Institutions to maintain 2009 as a final date for liberalisation of the postal sector in the EU" (PDF file) (31 May 2006)

Memorandum on Pluralism and Media Concentration addressed to the members of the European Parliament's Intergroup on the Press, Communication and Freedom (March 2005)

Safeguarding the future of the European Audiovisual Market - a white paper on the financing and regulation of publicly funded broadcasters (March 2004)

Media industry sets out market distortions and calls for rigorous application of state aid rules to publicly-funded broadcasters (PDF file) (March 2004)

SGEI green paper on services of general interest: position of the Coalition for Fair Competition in the services market (PDF file)

Speech by Commissioner Mario Monti: "Policy market definition as a cornerstone of EU competition policy" (October 2001)

Ad Hoc Alliance against unfair competition in the TV and new services markets (December 1998)

Protocol to the Amsterdam Treaty June 1997 on public service broadcasting

Informal comments by UNICE’s working group on State Aid

Amendment of the Transparency Directive

 

Consumer protection

Letter to Byrne in response to the Green Paper (January 2002)

Follow-up communication to the Green Paper on EU Consumer Protection (PDF file) (June 2002)

 

Content online

EPC response to the Commission consultation on content online (PDF file) (13 October 2023)

Harnessing the Full Potential of the Digital Economy - Comments from the Creative and Media Business Alliance on the European Commission’s i2010 Communication

 

Convergence

Memorandum to the Economic and Social Committee on pluralism and media concentration

Comments addressed to DG XIII for consideration in the preparation of the Green Paper on Convergence

Newspaper and magazine publishers' declaration on the rights of the content providers of Europe's information industry

Convergence of broadcasting, information technology and telecommunications. Response to Green Paper from the European Publishers Council

The Information Society Forum's First Annual Report: A critique (March 1997)

Response of the European Publishers Council to the Green Paper on the convergence of the telecommunications, media and information technology sectors and the implications for regulation (April 1998)

Newspaper and Magazine Publishers' Declaration on the Rights of the Content Providers of Europe's Information Industry

 

Copyright and the creative industries

Content sector common submission on the Green Paper on Copyright in the Knowledge Economy (PDF file) (28 November 2023)

iComp Seminar, Brussels: IP Issues and their Impact on Internet Commerce - speech by Angela Mills Wade (PDF file) (23 October 2023)

Comments of the European Publishers Council on the Second Call for Comments: ‘Fair Compensation for Acts of Private Copying’ (PDF file) (18 April 2023)

EPC letter: Taking Forward the Gowers Review of Intellectual Property - Proposed Changes to Copyright Exceptions ("the Consultation") (PDF file) (15 April 2023)

Comments of the European Publishers Council on Communication from the Commission on Creative Content Online in the Single Market (PDF file) (29 February 2023)

EPC response: Public consultation on the Review of EU Regulatory Framework for Electronic Communications Networks and Services (PDF file) (27 October 2023)

ACAP: A general briefing paper (PDF file) (05 October 2023)

Letter to Mr Shaun Woodward MP, following the Creative Economy Programme Publishing Summit on 4 September 2023 (11 September 2023)

Response from the European Publishers Council to the first evaluation of Directive 96/9/EC on the legal protection of databases (10 March 2023)

EPC response: i2010 - Digital Libraries (including Questions for online consultation 30.09.2023) (PDF file) (20 January 2024)

Réponse du Conseil européen des éditeurs (EPC): i2010 : Bibliothèques numériques (dont Questions aux fins de la consultation en ligne du 30.09.2023) (Fichier PDF en Français) (20 janvier 2006)

Harnessing the Full Potential of the Digital Economy - Comments from the Creative and Media Business Alliance on the European Commission’s i2010 Communication

Response from the European Publishers Council to the communication from the Commission draft evaluation of Directive 96/9/EC on the legal protection of databases (09 August 2023)

Letter to Madame Fourtou concerning Article 21 (07 October 2023)

Rightholders’ Coalition: "Copyright - root of Europe’s cultural heritage; key to its cultural future" (30 June 2023)

Response to the European Commission Green Paper on Public Sector Information in the Information Society

Copyright and the publisher

Position Paper on the Proposal for a European Parliament and Council Directive (97/0359 COD) on the harmonisation of certain aspects of copyright and related rights in the Information Society

"Creativity and Intellectual Property Rights: Evolving Scenarios and Perspectives" July 12-14 1998, Vienna (Panel on Moral Rights)

Why the Parliament was right to defend the need for strong copyright protection against piracy in the digital age

Conclusions of the International Copyright Conference - "European Copyright Revisited" (Santiago De Compostela, 16-18 June 2002) (PDF file)

 

Data protection and cookies

Response from the European Publishers Council to the Article 29 Working Document on Data Protection issues related to Intellectual Property Rights

EPC letter to Commissioner Erkki Liikanen concerning cookies

Contribution from the EPC on the review of the Data Protection Directive 1995/46/EC (30th August 2002)

EPC position on Article 9 of the Data Protection Directive

Recommendation 1/97 Data Protection law and the media

 

Ecommerce

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

Position paper of the European Publishers Council on the Draft Directive on Electronic Commerce

Proposal for a directive on certain legal aspects of electronic commerce in the internal market

Why an opt-out scheme for unsolicited commercial communications by electronic mail should be supported

Electronic commerce - A shopper's paradise or a regulatory nightmare?

FEDMA code on e-commerce and interactive marketing

Response to the consultation on the communication from the Commission to the Council and the European Parliament on European contract law (October 2001)

 

Environmental issues

Joint letter to Commissioner Dimas: Ecolabel for printed paper products - EU Commission’s impact assessment (PDF file) (15 March 2023)

European Recycling Forum Working Group D - Regulation: position paper from the European Publishers Council

 

Financial journalism

EPC Market Abuse fact sheet (February 2004)

Joint European Media Industry and Journalists Position on the Commission’s Directive on the implementation of Article 6§5 of the Directive on market manipulation (Letter to Commissioner Frits Bolkestein - January 2004)

Market Abuse Directive - EPC legal position (January 2004)

European Voice article on Market Abuse: Market abuse directive must be restrained - the future of financial journalism is at stake (03-09 October 2002)

Letter to the Financial Times from Mr Francisco Pinto Balsemão and others: CESR did not find out how media operate before publishing guidance (25 September 2023)

Financial Times leader on Market Abuse Directive: "From MAD to worse" (19 September 2023)

Letter to Robert Goebbels MEP concerning the second reading of the Market Abuse Directive (04 September 2002)

Joint Media Industry and Journalists’ position paper on the Draft Directive on Market Abuse: Addressing the threat to financial reporting (November 2001)

Market Manipulation - A letter to Bolkestein (13 June 2023)

 

Freedom of the press

Letter to the Culture Committee: Vote on 21/04/2023 on the Report by Marielle De Sarnez MEP regarding the proposal for a Draft Recommendation on the protection of minors and human dignity and the right of reply in relation to the competitiveness of the European audiovisual and information services industry (COM(2004)0341 - C6-0029/2004 - 2004/0117 (COD))

Media letter to President Prodi on Sexism Directive (09 July 2023)

Sexism Directive letter to Commissioner Diamantopoulou (01 July 2023)

 

Jurisdiction and applicable law

Joint publishers and journalists' letter on Rome II (11 January 2024)

Rome II joint publishers and journalists' letter to Members of EP Committee for Legal Affairs (15 December 2023)

Rome II joint position for second reading: Arguments for a complete exclusion of violation of privacy/rights of personality from the scope of Rome II (PDF file) (November 2006)

Rome II joint media and journalists letter to Commissioners (09 December 2023)

Rome II joint media and journalists letter to Commissioner Frattini (November 2005)

European media and journalists' position on Article 6 and other measures concerning the press - meeting of the Council Committee on Civil Law Matters (Rome II) (26 September 2023)

Joint letter to Ms. Diane Schmitt: European media and journalists' position on Article 6 and other measures concerning the press - draft Regulation on applicable to non-contractual obligations (Rome II) (19 July 2023)

Joint letter to the EP Committee for Legal Affairs: Rome II - Vote of the JURI Committee on the Report of Diana Wallis on the draft Regulation on applicable law to non-contractual obligations (Rome II)  (20 June 2023)

Joint media position for MEPs on the proposed Rome II regulation - defamation (29 November 2004)

Joint publishers' letter on Article 6 of Rome II draft Regulation - applicable law to defamation and privacy rights (30 September 2023)

The proposal for a regulation of the European Parliament and the Council on the law applicable to non-contractual obligations ("Rome II") - Submissions of the British media (14 November 2023)

Proposal for a regulation of the European Parliament and the Council on the law applicable to non-contractual obligations (Rome II) 2003/0168 (COD) (18 June 2023)

Contribution from the European Publishers Council to the Commission Consultation on a preliminary draft proposal for a Council Regulation on the law applicable to non-contractual obligations (13 September 2023)

EPC position paper on the draft Council Regulation on jurisdiction and the enforcement of judgements in civil and commercial matters

 

Media ownership

Memorandum on Pluralism and Media Concentration addressed to the members of the European Parliament's Intergroup on the Press, Communication and Freedom (March 2005)

SGEI green paper on services of general interest: position of the Coalition for Fair Competition in the services market (PDF file)

Krakow declaration: “A media policy for tomorrow" (June 2000)

Memorandum to the Economic and Social Committee on pluralism and media concentration

Draft proposals for a possible directive on media concentration and pluralism. EPC position sent to Commission President Jacques Santer and fellow members of the commission (February 1997)

Memorandum to the European Commission concerning proposed EU legislation on media concentration

Pluralism and media concentration in the internal market - Questionnaire no. III (April 1995)

 

Public sector information

Response from the European Publishers Council to the Commission Public Consultation on "Public Sector Information" (PDF file) (September 2008)

EPC response to the consultation on access to and exploitation of public sector information

 

Self regulation

Memorandum to the Economic and Social Committee on pluralism and media concentration

 

Services

COM 2004/0001 Directive on Services in the Internal Market and its effect on the advertising industry

 

State aid and Public Service Broadcasters

Press release: Unlimited expansion of public broadcasters into new media threatens development of commercial players (PDF file) (Brussels, 5 March 2023). Press release also in German and French

Comments from the European Publishers Council on the review of the Commission’s Communication on the application of state aid rules to public service broadcasting and a response to the questionnaire (PDF file) (March 2008)

Safeguarding the future of the European Audiovisual Market - a white paper on the financing and regulation of publicly funded broadcasters (March 2004)

Media industry sets out market distortions and calls for rigorous application of state aid rules to publicly-funded broadcasters (PDF file) (March 2004)

Ad Hoc Alliance against unfair competition in the TV and new services markets (December 1998)

Protocol to the Amsterdam Treaty June 1997 on public service broadcasting

 

Television without frontiers

Speech by Francisco Pinto Balsemão at the European Media Leaders Summit London (PDF file) (13th November 2006)

Speech delivered by Francisco Pinto Balsemão, Chairman of the European Publishers' Council at the World Museum, Liverpool on Tuesday 20 September 2005

Proposals for a revision of the "Television without Frontiers" Directive. Consultation on issues papers 2nd September 2005

"Television without Frontiers" Commission consultation - European Publishers' Council response (July 2003)

More information from the European Commission can be downloaded from the Europa website:

 

VAT harmonization

Letter to Commissioner Bolkestein on VAT (June 2003)

VAT statement addressed to the Romanian Government: "Don’t tax literacy, information, education and opinion"