In recent years public interest for the concept of vulnerable consumers has increased. In February 2013 the European Consumer Consultative Group (ECCG) published an Opinion on consumers and vulnerability. The ECCG argues that while the concept of “vulnerable consumers” was well-known, there was no commonly accepted or widely agreed legal definition due to the heterogeneity of this group. At the same time, the number of vulnerable consumers seems to grow in numbers due to an ageing population and high numbers of disabled citizens (currently there are 50 million in the EU).
The ECCG concludes that the specific needs of consumers who belong to a vulnerable consumers group should be identified and integrated more systematically and regularly into European and national policy making. Furthermore the perception of the “average” consumers – as opposed to the “vulnerable” consumers – requires re-thinking and adaption to a more modern and behavioural economics based approach.
Against this background the ECCG puts forward a number of recommendations such as:
- Undertake/commission targeted behavioural economics research and accident statistics data to gather more information about specific factors of vulnerability and their impact on certain categories of consumers;
- Redirect the EU legal benchmark of the average consumer towards a more realistic and people focused concept through an EC recommendation, which introduces a new and more flexible concept of a consumer-taking into account that consumers are often credulous and inexperienced and cannot take a lot of time and care to try to understand what is behind traders information and practices.
- Ensure that the needs of older people and people with disability are duly taken into account in other relevant Commission’s policies dealing with accessibility of goods and services.