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S P R I N G 2 0 1 9
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Union member states. However, the
HCA remains confident to take action
on an international scale and expects
international players to align their
practices with its guidance, where
relevant.
Super complaints: The HCA also put
forward its idea of "super complaints"
(i.e., such complaints that were sent
directly to the HCA by or through
authorities or consumer associations).
Although the HCA does not make
distinction between complaints, such pre-
selected and comprehensive presentations
by professional organizations may receive
more intensive and swifter intervention
by the HCA.
Fostering international cooperation:
The HCA concluded its strategy paper by
emphasizing its intention to accelerate
and strengthen international cooperation
around consumer protection, especially
within the framework of the Consumer
Protection Cooperation Network and
under the support of the European
Commission's New Deal for Consumers.
Evaluation
The HCA's strategy paper gives market
players insight into how the group
perceives market activities. The ambitious
undertaking to solve at least one novel
issue every year may represent an overly
eager approach to enforce competition
on the digital markets and among major
international companies. On the other
hand, it is arguable whether such a
strong approach from the HCA is indeed
necessary.
The HCA is definitely planning
to initiate an analysis of the online
comparison services market. Therefore,
undertakings, which perform such
activities, may expect data requests in
the near future. This inquiry is not
restricted to price comparison websites,
but extends to any online service,
which allows for product comparisons.
Furthermore, players, who also market
their own products through such services,
may expect a high level of scrutiny. The
HCA is likely to thoroughly control
whether consumers are provided with
all information regarding the basis of a
comparison and the proof regarding the
lack of bias in the algorithms.
All other undertakings, which are
active on the digital markets, may well
expect to be the target of HCA's scrutiny.
If the authority remains consistent with its
own goals and keeps providing guidance
regarding novel issues and compliance,
the number of tech companies approached
by the HCA may increase significantly
in future.