UNITED STATES COUNCIL FOR INTERNATIONAL BUSINESS
"U.S. Perspectives on Consumer Protection in the Global Electronic Marketplace - Comment, P994312."
The United States Council for International Business (USCIB) appreciates the opportunity to provide our views on Consumer Protection in the Global Electronic Marketplace in response to the Federal Trade Commission Request for Comment.
It is the view of the members of the USCIB that effective consumer protection is vital to ensure consumer trust in the online environment and consequently the continued growth of electronic commerce. To that end, business has developed and is continuing to develop technology solutions that empower the user to make informed decisions regarding online activities, codes of conduct, etc.
The USCIB would like to offer a set of evolving principles that our members believe should drive the debate on consumer protection in the context of global networks:
1. Policies should be market-driven and industry-led.
2. Policies should, where appropriate, be internationally compatible and should not impose a burden on international trade.
3. Premature conclusions on issues that are unresolved given the nascent state of electronic commerce (for example, choice of law) should be avoided. Such premature conclusions could have unforeseen negative consequences on the continued growth of electronic commerce.
4. Special consideration should be given to horizontal issues - the debate on consumer protection should not try to resolve issues that will have ramifications on areas beyond consumer protection.
5. There should be a maximum reliance on self-regulation as the means to best offer effective consumer protection in the dynamic and evolving online environment.
6. Consumer Protection policies in the context of global networks should not be more onerous than those guiding the offline environment.
7. Policies should be technology neutral and should be able to accommodate new and emerging online business models.
8. The objective of polices should be to promote consumer empowerment- policies should not be prescriptive.
9. Policies should promote rather than infringe upon the right of parties to enter into contracts on terms mutually acceptable to them.
10. Policies should recognize the special circumstances and interactive nature of the online medium: policies should be workable and implementable in the global networked environment.
Thank you for your consideration. Please do not hesitate to contact us if you have any questions regarding this comment.
Submitted: March 25, 1999