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With this statement, BusinessEurope and the signatory European sectoral employers express the clear message to public authorities and trade unions at all levels that European employers are committed to make their best efforts to continually employ and create new job opportunities in Europe, highlighting at the same time their needs to be able to do so.

The EU, in common with the rest of the global economy, is presently experiencing the deepest recession since the Great Depression of the 1930’s. Whilst the situation remains very uncertain, the European Commission forecast is for the EU economy to fall by about 8.3% this year, far deeper than during the Global Financial crisis in 2009.

Europe’s response to the crisis has so far allowed to contain the employment and social impact of the crisis in a more effective way than has been the case in other world regions. Strong and autonomous social partners in Europe have been an asset for rapidly designing and implementing fairly balanced crisis-related solutions, including the role of collective bargaining.

In particular, BusinessEurope and the signatory European sectoral employers have engaged in a variety of initiatives and activities in the last months, with their respective trade union counterparts, aiming to inform the European response to the crisis based on their real time analysis of economic and social trends deriving from the Covid-19 crisis.

Concretely, two trends have coexisted in the last months:

1. On the cross-industry level, there has been a stronger than usual focus on tripartite arrangements between governments, employers and workers

This has proven to be part of Europe’s resilience capacity, demonstrating its unparalleled social dimension, in particular to mobilise or create adapted short-time working schemes.
Short-time working schemes has so far largely saved the EU from the dramatic unemployment increases seen elsewhere, notably in the US. But without strong policy support for businesses and workers, unemployment levels could rise significantly above the 9% level the European Commission has forecasted for the EU in 2020, and will not return quickly to the 7.9% figure they forecast for 2021.

A key priority for cooperation between the European Commission, the cross-industry social partners and national governments in the coming months is to ensure that short-time work schemes are well coordinated at European level and well-performing in all EU Member States, making good use of the European financial support that will be available for countries in need via SURE. At the same time, these schemes are and should remain temporary in nature. They should be lifted in a flexible manner, adapted to the progressive release of containment measures. The role played by national sectoral social partners in their application needs to be taken into account.

The objective going forward is to encourage companies to fully recover their capacities as quickly as possible, ensuring a safe return to work for workers. The recovery plan just agreed by the European Council is a bold first step, and given its financial weight, it has the potential to make a real difference to boost investment and job creation by competitive companies, protect jobs and reduce business closures.

We now need to ensure that it is going to invest the resources made available on important and essential employment-enhancing structural reforms for our countries to strengthen their long-term growth potential. The way ahead is to improve the agility of labour markets, avoiding too strict regulations which act as a barrier to job creation.
While access to liquidity remains a key concern for many companies across Europe, we need to progressively move from a focus on the very short-term survival to the crisis, to investing into the future success of Europe by improving and mobilising our innovation and growth potential.

The European semester will play a key role. We count on the Commission and Council to ensure that the money foreseen in the Next Generation EU recovery instrument is well spent. Resources disbursement should be linked to the implementation of country-specific structural reforms.

2. The effects of this crisis have been far reaching throughout the economy

Some sectors in particular have suffered more dramatic consequences, as an immediate consequence of the lockdown measures. Negative impacts are more diffuse or protracted in other sectors, notably due to the lack of free movement of workers, supply chain disruptions at global level and within Europe and the related actual or expected impacts on production capacity. A high number of social dialogue solutions and initiatives have been introduced at sectoral and company levels as a response to this crisis.

In this context, BusinessEurope and the participating European sectoral employers recall the importance of:

• a growth strategy including the green and digital transitions but not limited to these two crucial transitions.

• a strengthening of key industrial value chains and ecosystems, and for the designing and implementing of a strong single market reform agenda.

• a solution to be designed now to ensure an adequate functioning of free movement of workers in the case of a second wave of Covid-19 or in view of a future similar sanitary crisis. Due to lack of preparation, many mobile and cross-border workers were not able to perform their duties in the last months because of different border crossing restrictions imposed by Member States. The situation has improved recently. But Europe still needs to secure the availability of an appropriate contingency measure that can be applied quickly and effectively if and when a similar situation would occur in future.

• The rolling out of the European skills agenda in close connection to industrial policy objectives and initiatives, as is rightly highlighted in the Commission’s New Industrial Strategy for Europe of March 2020. The nature of skills needs has not been significantly altered by the pandemic, most notably the need to achieve better results in terms of STEM, digital skills, and innovation. This is and remains about promoting a skill set that allows all workers to be able to use the technology they need to master to design and sell new products and services, such as information and data literacy, communication and collaboration, digital content creation, safety, problem solving. However, during this crisis, it became evident that a stronger focus on e-learning is needed due to limitations for in-person training in a context of social distancing. Concrete solutions also need to be found for vocational education and training which requires a lot of on-site exercises and more traditional competences. Moreover, a broadly social partner led approach to employee training and dual learning will deliver more effective and efficient outcomes than a purely individualised support mechanism, such as a learning account. We also consider the sector skills blueprints as a good initiative. European cross-industry and sectoral employers look forward to engaging with the Commission and with their respective trade union counterparts to make the proposed Pact for Skills a successful undertaking serving the needs of enterprises and workers.

• A science-based approach underpinning a safe-return to the workplace of all workers that have either been teleworking or working less due to the crisis’s economic impacts. Employers are committed to act in accordance with their legal obligations and responsibilities, which needs to be embedded into pre-existing employers’ risk assessment approaches. Public authorities at all levels need to avoid creating excessive additional obligations for employers, or unclarity as regards the application of public health crisis-related measures at the workplace. Moreover, effective solutions are needed e.g. for health and safety protocols at work, in line with diverse national industrial relations practices.

The way in which the sanitary situation will evolve in the coming months is to a large extent beyond human control. However, our collective capacities, responsibility and intelligence can help limit the spread of a future virus more quickly in a future occurrence.

In this period of economic difficulties and uncertainty, we have a plea for policy-makers at all levels to limit to the minimum the cost and administrative impacts of the measures they currently contemplate and to postpone their initiatives’ timelines where needed.

To conclude, European employers are ready to play their part, by focusing on what they do best: the design, marketing, production and distribution of innovative products and the provision of services that can offer solutions to the challenges of the 21st century while attracting customers globally and in Europe, to be able to create good and sustainable jobs across our continent.

A decade ago, the European Sectoral Social Partners, EPSU, UNI EUROPA, ETUCE, HOSPEEM, CEMR, EFEE, EuroCommerce, CoESS identified third-party violence and harassment at the workplace as one of the key health and safety challenges to face within the European Economic Area and signed the Multi-sectoral guidelines to tackle third-party violence (TPV) and harassment related to work. In 2018, EUPAE and TUNED joined these organisations in their work to tackle this pressing issue.

Since then, we have seen a progressive increase of awareness and procedures available against harassment and violence as well as to widespread availability of data related to physical violence, sexual harassment, and bullying/harassment at workplaces.

With the Guidelines, the EU social partners supported the creation of a multi-sectoral level playing field, contributing to a result-oriented policy at workplaces, and where practical steps are set up and can be taken by employers, workers, and their representatives.

The signatories acknowledged that, although there are sectoral and organisational differences concerning third-party violence faced by workers in different occupational sectors and workplaces, the key common elements of good practice and steps to tackle it include a social partnership approach, precise definitions, prevention through risk assessment in consultation with workers and their representatives, awareness-raising, training, clear reporting and follow- up, and appropriate evaluation processes.

EuroCommerce Director-General Christian Verschueren commented on today’s publication of the European Commission “Action Plan to fight against tax evasion and to make taxation simple and easy”:

“After 27 years of the supposedly complete single market, a more harmonised taxation system remains one of its major pieces of unfinished business. It should be the easiest thing in the world to operate a company cross-border in Europe, but, on top of other barriers, a burdensome and fragmented tax bureaucracy makes this a real headache.  Many governments have recognised, in the current crisis, that easing tax obligations are vital to supporting and driving economic recovery. If this is true now, it is equally important to address these barriers and burdens on a permanent basis.”

Retailers and wholesalers were hit hard by the outbreak of the COVID-19 pandemic, with many stores being closed and companies not being able to pursue their business. Many governments have provided temporary relief from bureaucratic burdens, be it through simplifying or delaying reporting obligations, or allowing digital filing. EuroCommerce has presented proposals for this to continue after the crisis, to Make VAT and Excise Duties Greener, Fairer and Simpler, including facilitated VAT registration and rules on food and other donations.

The fight against tax fraud, including deliberate undervaluation of goods imported from third countries, needs to be a priority objective of EU tax policy, while avoiding overburdening honest companies with bureaucracy. With all member states having to finance support to industry and employees, stopping revenue leakage through fraud is important now more than ever. It is also vital that Member States ensure a smooth implementation of the VAT e-commerce package by 1 July 2021.

Finally, Verschueren commented on the importance and urgency of securing a global agreement on modernising corporate taxation in the digital age:

 “Retailers and wholesalers across all business models strongly support efforts to find a common mechanism for corporate taxation at global level. We call on all parties to commit to complete the OECD negotiations as soon as possible. The alternative of a patchwork of national digital taxes leading to escalating trade wars and protectionism is definitely not an attractive one.”

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Together with 11 trade associations, EuroCommerce states its concern about the European Data Protection Board’s latest guidelines on consent. In light of recent decisions of the French Conseil d’Etat on cookies – highlighting that the GDPR does not ban cookie walls – the signatories call on the EDPB to uphold the flexibility of the GDPR and not to recommend more stringent norms.

More details can be found in the letter.

Ecommerce Europe and EuroCommerce today jointly launched the European Ecommerce Regional Report 2020. Growth in ecommerce sales reached €636 billion in 2019, up by 14.2% from the previous year. European ecommerce turnover is forecast to grow at around 12.7% and to hit €717 billion in 2020. The full impact of the COVID-19 pandemic on the sector will, however, only show next year.

This report comes out at a time of uncertainty all over the world. The COVID-19 outbreak, and the restrictions it has led to, have had a major impact on business and consumer confidence. While physical shops have maintained supplies of essentials, ecommerce has played a crucial role in maintaining economic activity in Europe. Retailers of all sizes have accelerated their digital transformation, further developing existing and new omnichannel commerce solutions.

Luca Cassetti, Secretary General of Ecommerce Europe, commented: “We are very proud of the resilience our sector has shown these last months and are delighted to see that the ecommerce industry has been successfully contributing to keeping the Single Market open. While the COVID-19 pandemic has revealed the strength of the digital commerce sector, it has also exposed the challenges online merchants still come across. Given the increasing cross-border nature of ecommerce, European businesses have struggled to implement new solutions across the Union due to regulatory fragmentation and diverging national approaches towards the crisis. In light of the current acceleration of the digital and green policy agendas, we need to step up our ambitions for building a stronger European Union with a truly harmonized Single Market.”

Christian Verschueren, Director-General of EuroCommerce, commented: “The COVID-19 pandemic has accelerated the pace of digital change in retail and wholesale. This trend will continue, and to gather further speed. People are now used to buying online, and will continue to do so. Our members are responding to this, but with difficult months - and probably years - ahead, we need urgent help nationally and at EU level to boost resilience and accelerate our sector’s digital transformation.”

The Ecommerce Regional Report 2020 sets out the main facts and figures related to the ecommerce sector in Europe, with country-by-country and sectorial analysis, interviews with heads of leading national ecommerce associations and other valuable information for merchants, policymakers and other stakeholders. Ecommerce Europe and EuroCommerce would like to thank the research institute RetailX for preparing and finalising this report and all the sponsors for their support.

To obtain the full version of the report, please visit this website.

NOTES FOR EDITORS

The 2020 report shows that Western Europe is still the most developed ecommerce market in Europe with 70% market share of the total B2C online turnover and the highest number of e-shoppers (83%), followed by Southern Europe with a 15% market share of the total B2C online turnover and the highest e-GDP (7.69%). Northern Europe (7%), Central Europe (6%) and Eastern Europe (1%) have the lowest market shares.

Other key trends identified in the report show that in 2019, the top three countries showing the most significant B2C ecommerce turnover growth were Romania (30%), Bulgaria (30%) and Spain (29%). Belgium (7%), Ireland (7%), Austria (4%) and Iceland (3%) showed the least growth in ecommerce turnover in the last year. Furthermore, the findings show that the country with the highest percentage of eshoppers (94%) in 2019 is the United Kingdom, followed by Denmark (86%) and Germany, The Netherlands and Sweden (all at 84%). The lowest percentages for online shopping were registered in 2019 in Bulgaria (31%) and Romania (29%). In terms of national and cross-border purchases, shoppers in The Netherlands (95%) and Poland (94%) mostly bought from national sellers, while Maltese (96%) and Cypriot (95%) e-shoppers are most likely to order cross-border (both from within the EU and non-EU).

Finally, the report includes interviews with leading national ecommerce associations, providing qualitative insights into the national ecommerce markets.

EuroCommerce thanks the Commission for the opportunity to contribute to the roadmap on the pharmaceutical strategy. EuroCommerce represents retailers and wholesalers in Europe. This contribution reflects the views of our full line pharmaceutical wholesale members.
EuroCommerce supports the broad objectives that the Commission puts forward with the strategy. The Covid 19 crisis has demonstrated the importance of ensuring universal health coverage and access to safe, consistent quality and affordable medicines for patients across Europe. Full line pharmaceutical wholesalers play a key role in the pharmaceutical eco-system and their role needs to be fully reflected when developing the strategy.
This paper focuses particularly on the role of full line pharmaceutical wholesalers and their role in the chain and the need for a resilient and well-functioning pharmaceutical eco-system to serve the needs of patients across Europe.

Full-line wholesalers play a key role in the pharmaceutical eco-system

Pharmaceutical wholesalers represent a vital link in the pharmaceutical eco-system, acting as a “one stop shop” for pharmaceutical products thanks to:

• Their sophisticated delivery systems covering the territory of all member states ensure that patients have access to vital medicines within hours of orders;
• Their negotiating power to ensure that patients have access to affordable medicines.
• Their contribution to the functioning and resilience of the pharmaceutical eco-system needs to be taken fully into account when designing and executing a pharmaceuticals strategy for Europe.

Pharmaceutical wholesalers employ 140,000 people and distribute 15 billion orders of medicines and a wide range of healthcare products in Europe every year. They provide facilities for the purchase and sale, warehousing, storage, and rapid order preparation and delivery of medicines. These wholesalers carry and distribute the full assortment of products to meet the needs of their customers and to deliver their medicines where and when they are needed. This ensures that patients’ needs are provided for efficiently and in real time. Similarly, manufacturers benefit from this timely, safe and reliable service to get their products to the patients who need them. In most countries, distribution of medicines is part of a public service function, largely performed by full-line wholesalers, and in some are subject to formal Public Service Obligations covering wholesalers and pharmacists. In this way, even in the most remote areas, patients can have access to the most vital medicines in a timeline manner. Classic full-line wholesalers earn a small percentage of the price of the medicines supplied. Delivering a full range of medicines allows for some cross-subsidiation, so that less expensive medicines, which carry a low margin, can be supplied at exactly the same quality and speed as expensive medicines.

Pharmaceutical wholesalers play an important role in ensuring patients have access to affordable medicines. They can use their negotiating power, volumes and assurance to manufacturers of efficient and timely delivery to promote competition on price and service levels to the benefit of patients.

Resilience during the COVID-19 crisis

The health crisis has hit European economies hard. In all member states, pharmacies, doctors and hospitals have been confronted with unprecedented levels of demand from patients. Full-service healthcare distributors were able to respond to the immense number of orders (some 2 to 3 times normal levels) in a timely manner through redoubling their efforts to ensure that confidence in the supply chain could be maintained.
The COVID-19 crisis has shown to policy makers and the general public the complexity of the supply chain. It has highlighted, sometimes through temporary shortages caused by bottlenecks or export bans in third countries, the global nature of manufacturing and product sourcing. It also underlined the importance of a well-functioning single market and the impact of public tendering practice on ensuring timely access to safe, quality and affordable medicine across Europe. Pharmaceutical wholesalers are part of the solution and are keen to see increased impetus for cooperation with other key stakeholders.

The crisis has also had a massive impact on pharmaceutical wholesalers’ margins. Wholesalers have worked hard to maintain continuity of supply against the background of extraordinary levels of demand. Any benefit of increased sales has been offset by higher costs due to disrupted supply chains, the need for additional staff and deliveries at short notice, and the measures to ensure safety of staff and customers. Pharmaceutical wholesalers have high fixed costs, and operate with low margins and regulated prices. The sustainability of their business model, and their margins, are under immense pressure.

Addressing shortages

The crisis highlighted the importance of the Single Market as a central driver of recovery. A recent study for the European Parliament estimated a potential economic gain of a properly-functioning Single Market of up to €713bn.

The free circulation of products is key to the resilience of the pharmaceutical eco-system, ensuring access to medicines across the European market and allowing a rapid and flexible response to shocks in supply or demand.
Export bans and trade restrictions are not an appropriate response to shortages of medicines, hit SMEs particularly hard and risk worsening the very situation which governments are seeking to solve:

• the accessibility of medicines across the world is linked to global manufacturing and product sourcing. These are complex supply chains, that can be easily disrupted, by e.g. availability of raw materials and active pharmaceutical ingredients, location of manufacturing sites and the need to ensure diversification of sourcing, pressure on cost management or external events disrupting the supply chain;
• a number of factors can cause medicines to become scarce or unavailable in a country, including market dynamics (e.g. low prices, low volumes, change in demand or manufacturers imposing quotas to gain better control of the supply of medicines in a given market) and regulatory and other issues (e.g. new regulation impacting costs, the availability of substitutes, licence withdrawal or export bans);
• governments’ tendering practices can have unintended consequences: where, for example, a tender gives the winning manufacturer the exclusive right to supply a specific medicine or category of medicines, the absence of alternative suppliers will cause shortages if the exclusive manufacturer suffers sudden production disruptions.

Parallel trading plays a key role in ensuring access to affordable medicines, by fostering competition and counteracting any producer and patent holder strategies to demand excessive prices in one territory. Parallel distributors find excess stocks in one country and offer them at a lower price in another. This creates competition and leads to significant savings. Parallel trade is not a significant cause of supply chain disruption and, by facilitating circulation of medicines, contributes to meeting shortages in one country by moving supplies from another.

We would further suggest the Commission to consider seeking to strengthen the WTO Pharmaceutical Agreement which was established in 1994 by a number of countries, including the EU. These countries cut tariffs on pharmaceutical products and chemical intermediates used for their production (the "zero-for-zero initiative"), including all active ingredients with a WHO International Non-proprietary Name (INN). The EU could consider, as part of the initiative, the possibility to call non-participating countries to join the WTO Pharmaceutical Zero-for-Zero Initiative and extend it to all pharmaceutical and medical goods.

Conclusion

On the basis on these points, we ask the Commission to take full account, when considering its pharmaceuticals strategy, of the role of full line pharmaceutical wholesalers as a central part of the supply chain, both in ensuring timely access to safe and affordable quality medicine to patients in Europe and in strengthening the resilience of the pharmaceutical ecosystem. We further ask the Commission to fully recognise the importance of a well-functioning single market and diversification of sourcing as key to the future of the ecosystem and the reliable and affordable supply of medicines across Europe, and to shape subsequent action to reflect and support this vital role.

EuroCommerce Director-General Christian Verschueren today welcomed the official launch of the new European Payment Initiative (EPI) consortium, to create a new unified payment scheme and solution, allow them to process instant or mobile payments, and set an alternative by-pass the major non-European card schemes.

“A new, fully European, payment scheme, independent of Visa and Mastercard, has been needed for many years in order to provide real competition. This is increasingly important now that merchants are seeing further increases in costs which are not regulated and by the reluctance of the Commission to expand the scope of the current Interchange Fee Regulation to address them. This initiative is therefore most welcome. However, at least four previous initiatives have all failed; this one will as well, if merchants, who are key to its success, are not full participants in the final solution being proposed.”

From a retail point of view, there are still significant areas of outstanding concern:

Customer journey. A seamless and simple user payment experience within physical stores, and in e&m-commerce, and supported by strong customer authentication (SCA), is deemed a critical merchant requirement.

Business case. We are unaware of the business model that the banks will adopt and whether there is a robust enough and transparent business case within it for merchants or to bring added value to their customers.

Governance. Is still a major concern. We don’t know what the final proposed governance structure will be and to what extent retailers will be represented or have a voice on the governance board.

Features & functionality. We still don’t have a clear idea of what the full scope of the EPI project will be, or the exact features their proposed new payment method will have or how it intends to embrace the benefits offered by Open Banking. For example, will it include payment reversals, notification of payment execution, dispute mechanisms, etc., from the outset?

Bank participation. In order for any proposal to be widely adopted throughout Europe, all banks need to participate; we consider pan-European reachability as critical to the success of the scheme.

Regulatory oversight. Regulators need to take active interest and be prepared to step in and take pro-active measures to address any issues or differences that may arise.

With the proper engagement of retailers and other users, this initiative creates a unique opportunity for real collaboration, for introducing effective competition into the payments arena and disrupting the current dominance of the two major schemes. This will, in turn, help ensure a seamless customer journey with benefits to all parties and substantially reduce the high cost of payments that our members and customers ultimately have to bear.

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Welcoming the updated EU Skills Agenda for Europe published today, EuroCommerce Director-General Christian Verschueren said:

“In our joint statement with our social partner UNI Europa at the height of the COVID crisis, we paid tribute to the millions of people working in our sector and called on national and EU authorities provide financial support in helping our workforce to up- and reskill. We will be looking to the Next Generation EU Recovery Fund, to help the retail and wholesale ecosystem in accelerating its digital and sustainability transformation and bolster its resilience in the face of the damage sustained during the crisis. One in seven Europeans works in retail or wholesale. We will need the European Social Fund and European Globalisation Adjustment Fund to be focused on helping our workforce in weathering these challenges.”

The lockdown due to the pandemic has accelerated and consolidated the shift to online sales. Employees now need to master digital systems and tools, and, in order to attract customers back into stores, to hone their interpersonal skills and the ability to offer informed advice.

Verschueren continues: “People must be equipped with the skills needed to take on new roles due to digitalisation, and to interact with new systems using blockchain and artificial intelligence. But they need also to enhancing their soft skills; retail and wholesale will remain a people’s business. So, it is about combining high tech and high touch.”

Our sector employs 29 million Europeans. Retailers and wholesalers are leaders in innovative Vocational Education Training (VET), for example, apprenticeships for retail professions are ranked first and second for young people in Germanyin popularity among all schemes across industry.  Employees in the sector are already trained in core employability skills. At company level, training programs have been tailored to the needs of employees and are teaching basic digital skills essential to their future employability.

Bipartite training funds are often part of collective agreements. The e-commerce merchant apprenticeships and related follow-on professional qualification adopted by Austrian and German social partners in retail and wholesale, are a prime example of social partner-induced innovation to meet the growing skills needs of employers in retail and wholesale.  Ongoing experiments in the Dutch retail sector with individual learning accounts in sectoral and company collective agreements, are another example of how these challenges can be met.

Yet, our sector faces skills gaps in many member states. National education and training systems urgently need updating to create curricula and qualifications to meet the needs of employers, and to give young people the best chance of getting a rewarding job. Private sector initiatives by retailers and wholesalers will continue to take up their role in meeting this challenge, but this will not be enough. Co-financing by the ESF+, especially for SMEs, will be vital for offering training for as many people as possible.In allocating EU funding from ESF+ to national programs, EU and national policy-makers should work with retailers and wholesalers to leverage the success of these private sector schemes to ensure that our employees obtain the right skills at the right time.

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The Single Market is still far from complete. In many aspects, the European Union is still a mosaic of 28 different national markets. This overview provides some examples of barriers that retailers and wholesalers face in the Single Market. We ask the Member States, the Commission and the European Parliament to address the barriers identified here. The best way for the retail and wholesale sector to provide jobs and growth is to create a business-friendly environment where there is full competition and consumers can enjoy a wide range of high quality and safe products.

The main problems that the retail and wholesale sector still faces are:

• Flawed implementation and application of the Services Directive that hinders the freedom of establishment, the free movement of services and the freedom to provide a service;

• National trade lawsthat hinder business in the way they do business. Often these laws hamper competitiveness of the sector, are protectionist and undermine business models that are genuine and legal business models in other Member States. Particularly concerning are developments in Central and Eastern Europe;

• National requirements that hinder the free movement of goods. Member States don’t notify new national technical requirements according to the procedure laid down in Directive (EU) 2015/1535, don’t apply the principle of mutual recognition in non-harmonised areas, goldplate directives, etc.

We also recognise some of the initiatives taken by the Commission to solve some of the examples mentioned in this paper. However, infringement procedures take a long time, are expensive and the outcome is uncertain. For businesses, this takes too long and they might decide to leave or not enter a market. In the end this deprives consumers of more choice, higher service and lower prices. EuroCommerce welcomes an open dialogue with the Commission, the European Parliament and the Member States to improve the Single Market for Retail.

This document is regularly updated. The previous update was done 19 December 2018.

EuroCommerce welcomes the opportunity to provide input to the roadmap consultations on an ex ante platform instrument and a possible new competition tool. Both areas are of high importance to the future and competitiveness of the retail and wholesale sector in an increasingly digital environment.

The Commission’s communication accompanying their proposal for a recovery package recognises that the retail and wholesale ecosystem has been hit particularly hard by the COVID-19 crisis. Confinement measures have significantly accelerated the move to online shopping and digitalisation, both for food and non-food products. Digitalisation has increased competitive pressure in our sector and the COVID-19 crisis has required immediate and substantial investment by retailers and wholesalers to meet unprecedented levels of demand or continue to serve customers. The crisis also illustrated that European retailers are exposed to competition from operators established outside the EU and selling direct to European consumers.

To remain competitive, retailers and wholesalers need a regulatory framework that supports strong European retail and wholesale ecosystems in a digital environment and gives them legal certainty and incentives to invest in robust omnichannel strategies. This framework must enable EU authorities to enforce EU rules towards all players on the European market – including non-EU traders in order to create a level playing field and ensure consumer safety.