Consumer Associations

Advance Copy

Introduction and About the Guideline

This guideline is developed for consumer associations in the Middle East and North Africa (MENA) region to:

- Improve understanding about their roles as consumer associations; - Setting up consumer associations; and - Facilitate engagement with consumer protection agencies in their respective country.

It is developed to provide understanding about nature of consumer associations their place in society and the needs they serve in the society. The guidelines include:

A. Consumer Associations: brief history, relevance B. Reference to consumer associations in the UN Guidelines on Consumer Protection C. Consumer Business / Operating model D. Collaboration with stakeholders in consumer protection especially consumer protection agencies: Strategies for consumer advocacy based on consumer issues: unfair business practices, anti-competitive behavior, unsafe products/services E. Support: references, case studies, international and regional collaboration, researches.

The guideline is arranged as follows:

- Key points - Texts, excerpts and research outcomes from authoritative documents and academic papers etc - Examples; notes; infographics and reflection

Consumer Associations Operating Ecosystem

Consumers are a dispersed group that lacks expertise and resources and is unlikely to be heard by regulators. Consumers in conflict areas and countries emerging from conflicts are disoriented and inadequately represented by a fragmented set of civil society organizations with limited resources and expertise.

Consumer associations are very much part of a larger ecosystem of consumers protection infrastructure and systems. A functional and effective consumer association makes significant and positive impact on the lives of consumers in the country and the region. Their effectiveness and the way they operate depend very much on national conditions such as consumer protection laws, culture and availability of local knowledge, researches and resources.

Figure 1: Consumer Organizations Operating Environment

At an organisation level, the operation of the consumer association is influenced by its statutes, available resources, local laws and work of other consumers or civil society organisations in the country – for example.

It may works with national research institutes (universities) or industry sector organisations on technical assistance or research. Consumer associations will need to find means to strengthen consumer representation by collaborating for example with research institutes.

The extent of the governments’ involvement in regional economic forums such as ASEAN, GCC and SADC, multi-lateral and bilateral trade agreements influences types

3 of products and services most available to consumers in a country and extent of consumer protection issues and policies.

The African Consumer Protection Dialogue (the 'African Dialogue') is an effort on behalf of African governments, NGOs, and the U.S. Federal Trade Commission to create informal opportunities to interface with each other, the U.S., and the rest of the world on consumer protection issues. Each month, African Dialogue teleconferences serve as the main forum for feedback and communication between participants. Recently, consumer agencies and NGOs from over 20 African countries have participated, including Egypt, Morocco, Tanzania, Uganda, Benin, South Africa, Nigeria, Ghana, Liberia, Kenya, Mauritius, Senegal, Cote d'Ivoire, Zambia, Angola, Mozambique, Tunisia, and others.

Box 1 : African Consumer Protection Network - example of regional forum1

International organisations such as the WHO, World Bank and UNCTAD offer a wealth of support to developing countries and least developing countries to address issues related to policies, infrastructure development, economic development and education in order to sustain economic growth of a country.

Several international networks and organisations also provide capacity building opportunities for civil society organisations (CSO) which include consumer associations. For example, in 2009/2010 a UNIDO project in Bangladesh included capacity building programme for the Consumer Association of Bangladesh (CAB).

At the local and national levels, consumer associations usually educate consumers, investigate problems, monitor compliance with standards and advocate change on behalf of the consumers. Regional and international organizations provide a forum for sharing experiences, permit multiplier effects and can mobilize international campaigns. When appropriate they can also advocate the consumer interest in the international arena2.

In the era of internet of things, the shared economy and millennial consumption trends the roles and responsibilities of consumer associations need to be redefined. This is discussed at the end of this guideline and describes briefly what consumer organisations can anticipate in the near and not so near future.

Choosing the appropriate representation for a consumer can be challenging. Given the complexity of modern society and the specialization that has occurred, citizens' groups are an effective means of integrating consumers’ interest into product safety policies for example. They provide a contact point of people with ties to the community and are able to develop the expertise for more effective consumer participation3.

1 Deon Woods Bell and Brian Lingela. The Fifth Annual African Dialogue Consumer Protection Conference. 10-12 September 2013. Zambia. https://www.ftc.gov/sites/default/files/documents/public_events/fifth-annual-african-consumer-protection- dialogue-conference-livingstone-zambia/10-session10.pptx 2 Food, Nutrition and Agriculture - 08/09 - Consumer Participation in Food Control (FAO - FPND - FAO, 1993) 3 Idem.

Abbreviations:

ACCP ASEAN Committee on Consumer Protection ASCOMA Association des consommateurs du Mali ASEAN Association of Southeast Asian Nations AusAID Australian Agency for International Development BIS Bureau of Indian Standard BMELV Tunisian Federal Ministry of Food, Agriculture and Consumer Protection CAB Consumer Association of Bangladesh CASE Consumers Association of Singapore CCC Forum Consumer and Community Communication Forum CI Consumers International COIC Community Opinion Investigation Committee CSO Civil society organisations EAP East Asia Pacific ECON Electricity Consumers’ Network (Karnataka, India) FAO United Nations' Food and Agriculture Organization FIAS Fiji Institute of Applied Studies FLE Financial Literacy Education GCC Gulf Cooperation Council GDP gross domestic product ICPEN International Consumer Protection and Enforcement Network ICRT International Consumer Research and Testing IEC International Electrotechnical Commission IOCU International Organization of Consumers Union IoT Internet of things ISO COPOLCO ISO's Committee on Consumer Policy ISO International Organization for Standardization ITU International Telecommunication Union JWSRB Jakarta Water Supply Regulatory Body KERC Karnataka, India Electricity Regulation Commission MENA Middle East and North Africa MRA Mutual Recognition Agreement NGO non-governmental organization OAS Organization of American States ODC Organisation for Defense of Consumers OECD Organisation for Economic Co-operation and Development PNG Papua New Guinea RACE Réseau associatif des consommateurs de l’énergie (Association of Energy Consumers in Cameroon) RSPO Roundtable for sustainable palm oil SADC Southern African Development Community SOE State Owned Enterprises UN ECE United Nations Economic Commission for Europe UNCTAD United Nations Conference on Trade and Development UNGCP United Nations Guidelines for Consumer Protection WCC Water Supply Customer Advisory Committees WHO World Health Organization WM Weights and Measures WTO World Trade Organization

List of Tables, Figures and Boxes

List of Tables

Table 1 : Various forms of Consumer Representation ...... 23 Table 2 : Example of consumer health and safety scandals (1930s to 2000s) . Error! Bookmark not defined. Table 3: Key considerations for the development of operating model of consumer associations ...... 27 Table 4: Collaboration Approach Snapshot based on possible objectives .... Error! Bookmark not defined. Table 5 : Methods and approaches collaboration with consumer protection agencies according to consumer interests ...... 40 Table 6 : Summary Checklist for Consumer Associations on Effective Collaboration Between Consumer Associations and Consumer Protection and Competition Agencies ...... 43

List of Figures

Figure 1: Consumer Organizations Operating Environment ...... 3 Figure 2: Sources of funding for various consumer associations ...... Error! Bookmark not defined. Figure 3 : World Bank - Options for Consumer Representation in the East Asia Pacific (EAP) Region...... 23 Figure 4 : Fake News about Parasite in Bottled Drinking Water ...... Error! Bookmark not defined. Figure 5 : Fake News about Fruits from Thailand Contaminated by HIV Blood Error! Bookmark not defined. Figure 6: EU recalls sweatshirt for girls due to strangulation hazard which maybe not eb an immediate threat or high risk to children in the MENA region...... Error! Bookmark not defined. Figure 7 : this recall may apply to those who own recreational water crafts. May only cover small number of consumers...... Error! Bookmark not defined. Figure 8 : this kind of product is used by large group of consumers and maybe relevant to consumers in most countries ...... Error! Bookmark not defined. Figure 9 : GDP (current US$) – for MENA region (Source:World Bank national accounts data, and OECD National Accounts data files) ...... Error! Bookmark not defined. Figure 10 : GDP per capita growth (annual %) - for MENA region (Source:World Bank national accounts data, and OECD National Accounts data files) ...... Error! Bookmark not defined. Figure 11 : Outline of Consumer Association Operating Model ...... 28 Figure 12 : Getting Consumer inputs (WB report on Consumer Representation and Regulations) ...... 34 Figure 13 : Consumer Outreach (WB report on Consumer Representation and Regulations) ...... Error! Bookmark not defined. Figure 14 : Example of Comparative Testing and Advisory Magazine (from CHOICE, Australia - left; and VOICE, India - right) ...... 37

List of Boxes

Box 1 : African Consumer Protection Network - example of regional forum ...... 4 Box 2 : Consumer Legal Action Fund of Hong Kong ...... 17 Box 3 : Consumer Associations in Volatile Economic Countries ...... 18 Box 4 : Example of Consumer Representation in Papua New Guinea, Senegal and India Error! Bookmark not defined. Box 5 : Mali - mechanism for regular consultation between government and consumer association Error! Bookmark not defined. Box 9 : Indonesia (water): The Jakarta Model for Consumer Representation ...... 32 Box 11 : Food Safety in MENA Region ...... Error! Bookmark not defined.

Table of Contents Introduction and About the Guideline ...... 1 Consumer Associations Operating Ecosystem ...... 3 List of Tables, Figures and Boxes ...... 6 1. Why Consumer Protection? ...... 9 1.1. Who is a consumer and why protect consumers? ...... 9 2. Consumer Associations and Movements ...... 12 2.1. What Are Consumer Associations? ...... 13 2.1.1. Brief History ...... 13 2.2. Why Consumer Associations? ...... 14 2.3 Funding ...... 15 2.3.1 Government grants ...... 16 2.3.2 Testing and Publication ...... 17 2.3.3 Membership Fees ...... 19 2.3.4 Assessment and certification (social standards) ...... 19 2.3.5. Development and International Grants ...... 21 2.4. Reference to consumer associations in the UN Guidelines on Consumer Protection ...... 22 2.5 Consumer Representation vs Consumer Association ...... 22 3. Consumer Associations Operating Model ...... 26 4. Collaborations Between Consumer Associations and Competition and Consumer Protection Institutions ...... 29 4.1. Pre-requisites for Effective Collaboration ...... 29 4.1.1. Laws and infrastructure related to consumer protection ...... 30 4.1.2. Policy calling for participation of consumer representatives ...... 32 4.1.3. System to collect consumer feedback, questions and complaints ...... 32 4.1.4. Laws or policies governing establishment of consumer groups, associations ...... 33 4.2. Modes and Approaches for Collaborations ...... 33 4.2.1. Consumer Awareness and Education ...... 34 4.3. Resource Barriers: ...... 37 4.3.1. Funding: ...... 38 4.3.2. Human / Staff: ...... 38 4.3.3. Equipment / Materials: ...... 38 5. New Challenges for Consumers Associations in the Digital Era ...... 44 6. Conclusions ...... 45 7. Resources ...... 46

7.1 About UNCTAD and MENA Competition and Consumer Protection ...... 46 7.2 Excerpts from UNGCP 2016 on Consumer Organisation and Groups ...... 46 References: ...... 48

1. Why Consumer Protection?

Consumer protection are related to activities by governments to intervene in business to consumer relationship to address issues related to unfair advantage businesses tend to have over consumers in the relationship. These advantages usually are in terms of product and service knowledge and also resources they have at their disposal. Consumers have difficulty understanding functions of ingredients (preservatives and food additives), active ingredients in medicine, automotive parts, finance and banking services (features, stock market, currency market, insurance premiums and interest calculations etc), data protection (cyber-security), dye in paints or even moving parts of a watch.

A typical consumer is often constrained by lack of scientific knowledge and information about safety and quality criteria and also risk assessment. Risk assessment forms decision making process in determining what is safe and not safe under any regulations. A Draft Consumer Protection Act of Egypt updates the definition of Government consumer protection interventions correct ‘consumer’ to include small traders market failures and equalize rights of consumers with and artisans, whose capital does traders and ensure that products and services meet basic not exceed five thousand Egyptian safety, environmental and performance requirements. It pounds.

also ensures that people have access to basic goods Box 1 : Definition of Consumer in Egyptian (food, water, sanitation and energy). Consumer Law

Addressing issues related to competition also improves operating conditions for smaller businesses and increases opportunities for growth.

1.1. Who is a consumer and why protect consumers?

The UNGCP provides a general description of a consumer:

“A natural person, regardless of nationality, acting primarily for personal, family and household purposes.”

Consumers need protection based on the notion that they will not know and read sales contracts or terms and conditions in small prints (especially) and what it means or even imply.

Even if they do read sales and purchase agreements can a consumer request the sales and purchase agreement for a house or car be amended before making the purchase or getting a loan?

The absence of organized voice or institutions for consumers poses limitation in protection of their interests in terms of acquiring products or services. The MENA region has seen growth and numbers of consumer groups and organisations. Their formation ranges from highly organized to fragmented. Some consumer associations which have sufficient resources publish education and information materials, have regional offices to receive consumer complaints, carry out seminars or even conduct comparative testing. Others may only represent consumer interests in managing complaints received.

In contrast, industry groups big or small have more resources and thus have unfair advantage over an individual (private) customer. They allocate resources and time to engage with

9 government agencies to understand product or services regulations in a country while others seek not to engage regulatory agencies to keep cost of compliance down.

Table 1 : Example of consumer health and safety scandals (1930s to 2000s)

History of consumer health and safety scandals

1930s Lash Lure Killing Mascara – used aniline dye, which was used for tinting leather and clothes. Highly toxic substance with paraphenylenediamine. Caused infection ulcers and scars, permanent blindness

Elixir Sulfanilamide Incident. Sulfanilamide, was used safely in tablet form to treat streptococcal infections. Increase in demand lead to change in formulation where sulfanilamide dissolved in diethylene glycol and was distributed in liquid form without toxicity testing. Caused kidney failure: stoppage of urine, severe abdominal pain, nausea, vomiting, stupor, and convulsions and death

1950s Morning sickness drugs - Released in the late 1950s, thalidomide was found to ease the effects of morning sickness - but withdrawn in 1962. Across 46 countries, over 10,000 children were born with defects like phocomelia. (discovered that it was capable of interfering with fetus development and cause birth defects.)

1960s Mass poisoning resulting from rice bran oil contaminated with polychlorinated biphenyls in Kyūshū, Japan – Yushu Disease.

1980s Spain - Thousands permanently damaged by eating industrial colza oil denatured with aniline and sold as olive oil possibly from tomatoes contaminated with insecticide.

Beech-Nut Nutrition Corporation in the United States sold artificially flavored sugar water as apple juice and was fined more than US 2 million.

Milk contaminated by dioxin - Belgium

1990s India - edible mustard oil adulterated with Argemone mexicana seed oil. Caused epidemic dropsy in thousands. Argemone mexicana seed oil contains the toxic alkaloids sanguinarine and dihydrosanguinarine. Over 60 deaths.

2000s Baby milk scandal, in China. 300,000 babies affected4..

Halal Lamb Burgers contained samples of porcine DNA, affected schools 19 schools in Leicester, UK5

Toy safety recalls – over 900 million toys recalled due to various safety risks to children – limits of lead (Pb) exceeded, physical characteristics posing harm to children.

Takata airbag recall, which involved 19 of the world’s biggest automakers and it’s estimated that as many as 49 million cars could have the dangerous airbags worldwide.6

4 Forbes. The 2008 Milk Scandal Revisited. 07/16/2014. https://www.forbes.com/sites/yanzhonghuang/2014/07/16/the-2008-milk-scandal-revisited/#170a1bbf4105 5 BBC NEWS. Leicester schools halal lamb burger contained pork. 05/09/2013. https://www.bbc.com/news/uk-england-leicestershire-22466068 6 Consumer Report. Takata Airbag Recall: Everything You Need to Know. 07/18/2018. https://www.consumerreports.org/car-recalls-defects/takata-airbag-recall-everything-you-need-to-know/

Consumer protection and competition agencies are also challenged by advantage industry and businesses have in terms of product and service knowledge. The rapid technological advancement and short product life-cycle (mobile phones and tech-gadgets especially) poses regulatory challenges to authorities and consumer associations.

Due to different conditions for products along the supply chain, it is difficult to ensure zero-risk for products or services. That is why consumers need access to systems which readily capture safety incidents and information about consumer detriments. Without such system or facilities consumers tend to rely on social media news.

Consumer associations have the potential to mend this information gap and influence policy makers to improve consumer safety laws and policies.

Some consumer organizations in developing countries usually rely upon information from industrialized countries but often these may not apply to local or national situation. This happens when local resources and researches on local conditions are often difficult to access or not available. For example, consumer associations in MENA region may want to know the list of unsafe products recalled from the market. There is no centralized site or facilities to seek such information. The next option is to see if any of the more developed countries in the MENA region have such facilities and if none, more global database can be consulted such as the EU RAPEX or the Australian Product Safety database.

EU Recall News (RAPEX) :

Figure 2: EU recalls sweatshirt for girls due to strangulation hazard.

Figure 3 : this recall may apply to those who own recreational water crafts. May only cover small number of consumers.

Figure 4 : this kind of product is used by large group of consumers and maybe relevant to consumers in most countries

Active participation and involvement by consumers and access to objective and adequate information enhances consumer confidence in the national consumer protection system.

Among the first elements to include in the consumer protection and competition policies is to have an open and transparent consumer involvement and participation in decision making process. This facilitates further collaboration between associations and agencies in the interests of consumers in the country.

2. Consumer Associations and Movements

Collective citizens and consumers movement (in the form of national association or international organizations) are important in our economic system because they can compel corporations to improve ethical business practices. Consumer associations can also influence consumer friendly policies in uncompetitive market environment in utilities services such as water and sanitation services.

Here we have some examples about what we talk about:

• Nike sweatshops came under media spotlight for unsatisfactory working conditions and substandard pay for workers mainly in developing countries. The campaign against Nike impacted its bottom line and it doing things in a much more open and transparent way7. • In 2010 Greenpeace highlighted that Kit Kats uses palm oil from sources which were destroying the rainforests and habitats of orangutans. Using massive social media campaign, Greenpeace made Kit Kat to cut all ties with the company that was providing the palm oil. Kit Kat later pledged to use only roundtable for sustainable palm oil (RSPO) certified ingredients8.. In 2016, Seaworld ended its orca breeding programs. • During last years in Mexico, consumers associations have achieved that multinationals like Coca Cola or Kellogg’s stopped to spread misleading adds about their false

7 The Nike Controversy By Matt Wilsey, Scott Lichtig https://web.stanford.edu/class/e297c/trade_environment/wheeling/hnike.html 8 Greenpeace, Nestlé in battle over Kit Kat viral ; By Paul Armstrong, CNN March 20, 2010 - http://edition.cnn.com/2010/WORLD/asiapcf/03/19/indonesia.rainforests.orangutan.nestle/index.html

healthy properties of their food910. In addition, in Spain associations have gotten that banks change their abusive conditions11.

As we can see, consumers movement could achieve big things in benefit of the society.

2.1. What Are Consumer Associations?

Generally, consumer associations are non-government or civil society organizations representing citizens or group of citizens’ interests in terms of protecting their rights to goods and services under an ethical trading environment. They are usually non-profit making and are free from government or business influence but maybe fully or partially financed by the government or any other agencies.

The consumer movement and organized consumer movement in the form of consumer association is not a recent phenomenon.

2.1.1.Brief History

Earliest signals of consumers movement have taken root during the XIX century. Then, activities were concerned with the rights of all to participate in consumer society, be these concerned consumers connected to the National Consumers Leagues of Continental Europe and North America, the anti-sweting campaigns in Britain or the living wage campaign of the US labour movement 12 . Later, in 1928, Consumer Union was created, they are the first consumers association as we known today and they focused on testing similar products range from different brands and published these results periodically13.

Then, in 1960, several of the United States and European organizations came together to form the International Organization of Consumers Union or IOCU which is the predecessor of the current Consumers International or CI. With the momentum for organized consumer movement picking up in Southeast Asia, IOCU set up its first regional office for the Asia-Pacific area in Penang, Malaysia. Its first regional director was Dato’ Dr. Anwar Fazal from Malaysia.

About the same time organized consumer movement began to take root in Southeast Asia: Consumers’ Federated Groups of the Philippines – 1963, Selangor Consumers’ Association - 1965, Consumers’ Association of Penang - 1969, Consumer Association of Singapore -1971and Indonesian Consumers’ Organization – 1973. Consumer associations in the Middle East and North Africa (MENA) region seemed to have gained traction in the 1990s and many of the national consumer protection laws were enacted around the 1990s and 2000s.

9 Coca Cola deberá retirar campaña '149 calorías' por engañosa, afirma ONG. July 22,2013. http://www.elfinanciero.com.mx/empresas/coca-cola-debera-retirar-campana-149-calorias-por-enganosa-afirma- ong 10 Retiran publicidad de Zucaritas por afectar habitos alimeticios. July 19, 2007. http://archivo.eluniversal.com.mx/articulos/41481.html 11 OCU consigue que el Tribunal Supremo declare abusivas 32 cláusulas de contratos de BBVA y Popular. January 22, 2016. https://www.ocu.org/organizacion/que-hacemos/logros/stacasuelo 12 Hilton Mathew. The Death of Consumer Society. In: Transactions of the Royal Society. 2008. Pag. 213. 13 In 2012 there were eight such associations in the US with annual revenues in excess of US$ 2 million. Examples of these publications are the Consumer Report (US), Choisir? (France) and Test (Germany). The US Consumers Union had revenues of US$ 250 million and three others had budgets in excess of US$ 8 million. The more affluent consumers at that time purchased or subscribe these magazines or publication to help them make informed purchasing decisions

Finally, in Latin America, the consumers associations were developed later, during de decade of 1980 in Brasil, Uruguay y Argentina14.

2.2. Why Consumer Associations? Consumer associations as one form of civil society help governments and businesses maintain higher level of transparency and accountability in offering consumers products and services. A legitimate consumer organization can improve governance process pertaining to market activities. They are the voice of consumers in the governance process, representing the consumer’s interest by improving balance of power between consumers and businesses to be more equal15. They are for example: • analyst and advocates, • educators, • monitors, • risk managers, and • information providers

The need for collective and organized consumer movement mostly in the form of consumer associations or organisations is based on:

• the need for an independent actor which is apolitical and non-profit to represent consumer voice and anticipate impact of a given issue on consumer well-being; • the need to represent views of under-represented group of consumers namely those who are illiterate, in rural and remote areas and disadvantaged; • the need to improve bargaining power of the under-represented group of consumers; and • The need for authorities to be alerted about the illegal conduct of companies.

14 SANCHEZ LEGRAN, Paco and LUIS MURILLO, Paco. El Movimiento de Defensa de los Consumidores en América Latina y el Caribe. Fundación FACUA para la Cooperación Internacional y el Consumo Sostenible. 2011.Pag. 31. https://www.fundacionfacua.org/documentos/libro_america_latina.pdf 15 HUONG HA and SUE L. T. MCGREGOR. Role of Consumer Associations in the Governance of E-commerce Consumer Protection; Journal of Internet Commerce, 12:1, 2013.

Among the major roles of Consumer Associations are16:

• Monitor the compliance with regulation and guidelines; • Provide a platform and activities for dispute resolution. • Cooperate with other stakeholders to educate consumers on how to manage risks in purchasing. • Cooperate with other stakeholders to identify offending businesses and work with relevant enforcement agencies. • Research and surveys of consumer views and expectations • Advocate policies relating to consumer protection and competition (campaigns, education, community meetings etc). • Publish relevant information about consumer protection to make the public aware of current and new issues and how to avoid being cheated

Besides legal and political challenges in the country where they operate, consumer associations often face financial challenges to sustain their work. Typical sources of funding for consumer associations are donations, subscription, cooperatives and state sponsorships.

2.3 Funding

Consumer associations should diversify their funding sources to remain financially sound and sustain their consumer protection activities and not risk their independence and integrity. Many consumer associations in developed countries have a reasonably strong financial footing in the sales of their magazines. This is believed to improve resiliency of the consumer associations in time of financial crisis. In developing countries however, this is not the case.

Consumer associations in developing countries often do not have a large subscription base to depend on for magazine subscription. The bulk of their funding is frequently from external sources and they are therefore vulnerable to restrictions applied by donor agencies (which may include their own Governments) to focus on particular issues in particular areas or not to do so.

In most countries there is formal or dedicated government support for consumer organisations. Financing from either industry or Government poses problems of independence. Some publicly funded consumer bodies have managed to maintain a high profile and maintain autonomy in policy making.

16 Idem.

Examples:

1. CASE – Singapore 2015 ; Income: • Grants/Sponsorship - 26.6% • Investment Income - 30.8% • Other gains and tax deduction - 42.6% 2. Consumer Council of Fiji – Annual Statement 2013 ; Income: • Grant from Government of Fiji – 96% • Other grants – 4%

3. Consumer Energy Alliance, Australia - 2016 Annual Report; Income / Revenue • Members and Operational Services - 90% • Energy Day - 10% 4. Consumer Council Hong Kong – 2016 Income: • Government subvention - 85% • Non-recurrent projects subvention - 10.4% • Sales of CHOICE Magazine - 1.9% • Others - 3.2% 5. Consumer Report – US 2016 Financial Report – Income / Revenue

• Subscriptions, newsstand, and other sales - 86.6% • Contribution - 11.6% • Others - 1.8%

Figure 5: Sources of funding for various consumer associations

Thus, there are several funding model for consumer associations. Among others, being:

1. Government grants 2. Testing and publication subscription 3. Membership fees 4. Assessment and certification (social standards) 5. Development grants

2.3.1 Government grants Some countries have arranged a part of the national budget to protection of consumers by financing consumers associations. Because consumers protection is a priority and the consumers associations help about this goal, governments give funds to they could work in favor of the citizens and the economic system.

For example, the Consumer Welfare Fund of India has been set up by the Department of Revenue and, is being operated by the Ministry of Consumer Affairs, Food & Public Distribution, Department of Consumer Affairs. The Consumer Welfare Fund Rules were framed and notified in the Gazette of India in 1992. The Fund was setup with the objective of providing financial assistance to promote and protect the welfare of the consumer, create consumer awareness and strengthen consumer movement in the country, particularly in rural areas. Under the Consumer Welfare Fund Rules, any agency/organisation engaged in consumer welfare activities for a period of three years and registered under the Companies Act, 1956 or any other law for the time being in force, village/mandal/Samiti-level cooperatives of consumers, industries State Government etc are eligible for seeking financial assistance from the Fund.17

The Malta Voluntary Organisations Project Scheme is an initiative which falls under and is managed the Ministry for Social Dialogue, Consumer Affairs and Civil Liberties (MSDC), and is

17 Ministry of Consumer Affairs, Food and Public Distribution Consumer Affairs Apartment. Consumer Welfare Division. Fund https://consumeraffairs.nic.in/forms/contentpage.aspx?lid=73

16 administered on its behalf by the Malta Council for the Voluntary Sector (MCVS). The Voluntary Organisations Project Scheme is an allocated fund of €700,000.00. The call for applications is issued by the Ministry for Social Dialogue, Consumer Affairs and Civil Liberties under the Voluntary Organisations Projects Scheme herein referred to as VOPS. The guidelines for the VOPS are published on the Malta Council for the Voluntary Sector website www.maltacvs.org and the New Funding Portal www.vofunding.org.mt.18

Moreover, the Ministry of Industry, Investment, Trade, and Digital Economy, Morocco launched financial support for the consumers associations in 2016, in order to provide assistance in education of consumers in Morocco. To date the ministry provides support to about 100 consumers associations.

In the 1970s, in United Kingdom, consumer protection becomes its priority and a development grant from the Government was given to the national charity, the National Association of Citizens Advice Bureaux (NACAB), to extend the network. In 2002, NACAB (Citizens Advice predecessor) receives a £20 million grant from the Government's Capital Modernisation Fund to provide IT infrastructure to roll out e-government services to Citizens Advice service clients19. In 2003, NACAB changes its name to Citizens Advice20. In addition, Citizens Advice UK receives core funding from the Department for Business Innovation and Skills (BIS)of UK.

The Hong Kong Consumer Council is the Trustee of the Consumer Legal Action Fund through a Declaration of Trust executed in November, 1994. The Fund was established with a Government grant of $10 million, a further sum of $10 million was granted by the Government to the Fund in May 2010. The Fund aims to give easier consumer access to legal remedies by providing financial support and legal assistance for the benefit of consumers, particularly, groups with similar grievances in cases involving significant public interest and injustice.

Box 2 : Consumer Legal Action Fund of Hong Kong

2.3.2 Testing and Publication

The success of this funding model in the US quickly spread to Europe. The US consumer testing associations provided the initial financial support to the United Kingdom Consumers Associations in the 1950s for product testing and publication of the magazine. This magazine called Which? reached one million subscription at its peak. Similar success was seen in Belgium, Germany and Denmark. These operating models was run based on commercial methods but with non-profit principles. In countries like Norway and Austria and Sweden the testing and publication was supported with some government subsidies.

18 Voluntary Organisations Project Scheme (VOPs)http://maltacvs.org/voluntary-organisations-project-scheme-vops/ 19 Citizens Advice. History of the Citizens Advice Service. https://www.citizensadvice.org.uk/about-us/how-citizens-advice-works/who-we-are-and-what-we-do/history-of-the- citizens-advice-service/ 20 The Citizens Advice of United Kingdom is a registered charity in the UK. It is a national charity with 307 local Citizens Advice members which are all individual charities in their own right and together make up the Citizens Advice service. It provides free, and independent advice to help people overcome their problems, represent citizens’ voice through policy advocacy and campaigns. Citizens Advice Bureaux was established in 1939 throughout the UK to address social disorganization during the great depression.

As testing is inherently expensive it makes sense to pool resources to carry out testing on products which are globally available – electrical goods, packaged / processed food and cosmetics. Large consumer testing organisations came together in 1990s and formed the International Consumer Research and Testing or ICRT - a global consortium of 35 consumer organizations in 33 countries dedicated to carrying out joint research and testing in the consumer interest. ICRT runs more than 50 large joint tests and numerous smaller joint tests each year and can reduce significantly the costs to smaller organizations as a result of resource pooling.21 Consumer organisations in Thailand and Indonesia are members of ICRT and often carry out joint testing to manage cost of testing for products marketed in Thailand and Indonesia respectively.

There are vast differences between the ways Algeria intends to: consumer associations operate, often depending on the economic status of the • develop the ability to perform comparative testing country. In economies where consumers are well- of products and services; • Improve consumers’ awareness of their rights educated and have higher per capita income, comparative testing and providing credible among others to prepare Algerian consumers to face information to consumers has been the main role the challenges of the 21st century of many consumer organizations. Millions of (taken from presentation of the Algerian delegation at the consumers subscribe to their magazines and are UNCTAD MENA program workshop in Egypt February 2018) willing to pay for the information and advice in Tunisia has a national network of 230 Laboratories the magazine about products and services. (excluding health) analysis and testing laboratories of which 62% are in the public sector and 74 accredited In developing countries, consumer associations laboratories. Consumer associations have access to provide more basic needs services and may be infrastructures in the country to organize comparative involved at the local level in educating and testing on consumer products provided funding is available to pay for the tests and acquisition of outreach to consumers regarding their rights and samples from the market. also representing consumer interests at the Box 3 : Consumer Associations – comparative national policy development. A key factor to testing in the MENA region. ensure the credibility of consumer associations is independence, both from businesses and political causes. The financial viability of consumer organizations may pose difficulties when it comes to holding on their independent status.

21 UNCTAD. Manual on Consumer Protection. Advance Version. 2016. Pag. 34. https://unctad.org/en/PublicationsLibrary/webditcclp2016d1.pdf

2.3.3 Membership Fees

Consumer associations also generate income through membership fees. Smaller consumer associations scattered over large geographical areas can come together to form a coalition or federation. The smaller consumer associations presumably pay membership fees and appoint council members who will represent their association’s interests in the coalition or federation. A coalition of consumer association of this kind provides a stronger platform for consumer voice to be heard at a national level and get the attention of the relevant government agencies or policy makers.

One of the challenges in this type of income generation is the difficulties faced by secretaries and treasurer to collect the membership fees on a regular basis. Often membership fees do not form a major income portion for consumer associations especially in least developed or developing countries where the members they represent are poor and not able to make ends meet.

In most cases, members of consumers associations get benefits such as counseling, legal defense and the magazine that includes the results of testing products. In this way, comparative testings become a tool to promotion membership. In many countries, like the United States (Consumers Union), Spain (Facua), New Zealand (Consumer New Zealand), Peru (Aspec), there are associations that make campaigns to gain more members, not only to increase their income but also to have a higher legitimacy in the demand for consumers rights.

2.3.4. Assessment and certification (social standards)

Consumers associations like the Consumers Association of . Singapore (CASE) have developed accreditation services used by businesses to show compliance with fair trading and consumer protection requirements. This accreditation scheme is called Case Trust. It was an accreditation scheme targeting the service and retail industry. CaseTrust’s standards are developed and managed in an unbiased manner. Representatives from STB, SPRING Singapore, IDA, NATAS, and CASE volunteers are all members of the CaseTrust Advisory Council, giving the Secretariat in sights and directions forward. A shop which displays the CaseTrust Logo signifies fairness and honesty in its dealings with consumers.

The Consumer Recommends endorsement programme enables New Zealand consumers to recognize consumer recommended products, helping them make informed decisions.The brand mark is available to manufacturers, distributors and service providers to use in advertising and promotion. It can only be used for those products and services that have been awarded Consumer Recommends status, subject to meeting license conditions.

The Consumer Recommends brand mark may be used directly alongside the endorsed product. Manufacturers, distributors and service providers whose products have been awarded Consumer Recommends status are eligible to purchase a non-exclusive license to use the brand mark in their advertising and promotion. License renewals are considered on a case-by-case basis.22

22 Consumer New Zealand. About Consumer Recommend

There are not many consumers associations that replicate such schemes because of risk of being perceived as biased towards certain businesses. Consumer associations which run such schemes need to be transparent in terms of how the scheme is developed and managed independently.

https://www.consumer.org.nz/topics/about-consumer-recommends

2.3.5. Development and International Grants

Consumer associations can also access grants offered by international grant making or development organisations.

Australian Aid (AusAid) provides grants to the ASEAN Committee on Consumer Protection through its ASEAN-Australia Development Cooperation Program (AADCP) Phase II. This is a long-term (2008-19), €57 million program that supports ASEAN‘s goal of establishing an ASEAN Economic Community by 2015 and the post-2015 vision23.

The Anne Fransen Fund’s mission is to advance the position of consumers in developing economies through building consumer organisations and funding campaigning projects. The fund itself is made up of contributions from individual members of the Dutch consumer body. Each year, grants of up to €10,000 are awarded to Consumers International members to carry out projects linked to one of the eight basic consumer rights24. Consumer associations who are member of Consumers International qualify to apply for the Anne Fransen Fund. Smaller consumer associations are usually preferred to receive funding from this fund.

Larger more established consumer associations can often apply for grants from the European Union, Deutsche Gesellschaft für Internationale Zusammenarbeit - GIZ and Swedish International Development Cooperation Agency – SIDA provided they meet organizational requirements which are usually quite strict. GIZ is a German based provider of international cooperation services for sustainable development and international education work. GIZ works with businesses, civil society actors and research institutions, fostering successful interaction between development policy and other policy fields and areas of activity.

SIDA is a government agency working on behalf of the Swedish parliament and government, with the mission to reduce poverty in the world. SIDA carries out enhanced development cooperation with a total of 36 countries in Africa, Asia, Europe and Latin America. SIDA has funded several capacity building progamme with the International Organisation for Standardization or ISO on national quality infrastructure and international standards development. One of the key projects of SIDA in this area is the promotion of the ISO 26000:2010 Guidance on Social Responsibility standard in the MENA region. Among the core principles of the ISO 26000:2010 is consumer issues. 25

The Ministry of Industry, Investment, Trade, and Digital Economy of Morocco received funding from the European Union to fund a 27 month twinning program with France (DGCCRF and INC) and Belgium (ABREOC) in April 2015. The twinning program is intended to reinforce the Morocco’s participation in the international and regional initiatives related to consumer protection through facilitation of information exchange on national policies and best practices related to consumer protection. The information exchange includes among consumer associations.

23 ASEAN-Australia Development Cooperation Program Phase II (AADCP II). About us. http://aadcp2.org/about-us/ 24 Ann Fransen Fun. Consumers Internacional. https://www.consumersinternational.org/what-we-do/grants/anne-fransen-fund/ 25 Swedish International Development Cooperation Agency - SIDA. Our Mission https://www.sida.se/English/About-us/Our-mission/

In Jordan seminars/workshops on best international practices of consumer protection within the framework of Jordan's consumer protection draft law were organized with the support of USAID Program

2.4. Reference to consumer associations in the UN Guidelines on Consumer Protection

Reference to consumer associations in the UNGCP is made as consumer organizations and consumer groups and encouraging member states to work in collaboration with them and other stakeholders in:

i. Monitoring fraudulent business practices ii. Monitoring claims – example environmental claims iii. Monitoring marketing and developing marketing codes iv. Strengthening understanding among consumers on dispute avoidance and dispute resolution v. Involvement in general consumer education and information programmes vi. Undertaking education and information programmes vii. Facilitating cooperation with the aim of strengthening capacity in sustainable consumption

2.5 Consumer Representation vs Consumer Association

Many government agencies define consumer representation as an act on behalf of consumers by individual or organization which voices consumer perspectives and takes part in the decision-making process on behalf of consumers.

Government and private sector associations (including international organization) often outline characteristics of those representing consumer interests as those with large membership and at least significant geographical representation.

Smaller and new associations often have representation challenges. A consumer representative need not be a consumer association. It can be an individual – for example:

• a retired professor who wants to advance healthcare for the rural poor; • a university student who assists women in the community to better manage their finances; or

• head of community engaging with local authorities for price monitoring of basic goods in his community.

Figure 6 : World Bank - Options for Consumer Representation in the East Asia Pacific (EAP) Region

Donor or grant agencies such as the USAID often emphasize strength of representation in order to offer grants as this lends credibility to the work of the associations and due diligence by donor or grant agencies. The credibility of the whole organization is at stake when a consumer association is called upon to represent the consumer interest.

Table 2 : Various forms of Consumer Representation

Mechanism for Consumer Pros Cons Representation In-house consumer affairs • Easy access to reliable information on the • Limited scope of action to challenge bureau regulatory process. regulatory decisions due to lack of • Synergies between consumer independence from the regulatory agency representation and regulatory functions-- itself. in-house consumer affairs bureaus are well placed to solicit consumer information that can be used to inform the representative function.

Board representation • Powerful channel of information for • Inadequacy of representation, if the board (by Consumer Associations, consumer groups (if there is no duty of members in charge of consumer Civil Societies) confidentiality). representation are captured by special • Very fluid exchange of views between interest groups and/or they are not fully consumers and regulators, if consumer accountable to the consumer constituency. input becomes an integral • Too many conflicting interests within the part of the decision-making process. regulatory body may result in stalemate of the regulatory process.

External advisory body • Capacity to challenge regulatory • Inadequacy of representation, if the decisions, due to the body’s advisory body is captured by the most independence from the regulatory influential consumer groups. agency itself.

A number of points need to be taken into account when acting in a representative capacity:

Legitimacy in the context of consumer association may refer to the recognition by consumers that a consumer association or organization genuinely represents their rights and interests. Legitimacy can be characterized by components such as participation, fairness and accountability. Ensuring legitimacy strengthens the views and voice of the stakeholders they represent.

Consultation is an essential feature of true and effective representation. The absence of a significant membership and established consultation mechanisms can compromise their representative role. Can consumer organizations with limited membership truly claim to represent the consumer interest? Can consumer associations really be more successful in setting priorities, identifying regulatory targets and implementing strategies than public agencies? Many strive to be representative of the consumer interest. In order to do so, a broad membership base and consultation mechanisms with the membership could help. 26.

Small organizations will have difficulty in securing a representative role when starting out, especially when articulating a specific issue, which may have developed rapidly, for example in response to a public health emergency. Groups that are critical of, or distrusted by, Government agencies often have difficulty in gaining access to information and in being included in the consultation process. Such exclusion narrows the policy making process and denies the expression of a diversity of views27

In order to be effective in their work consumer associations need to develop the necessary capacity: skills, qualification, financial resources and local knowledge of how things get done (culture, demography). Basic tools such as satellite phone, a mobile phone to facilitate communication and information exchange are very useful in rural and remote areas or while in the field. An institutional backing such as village community bodies, religious bodies and local government will go a long way in educating consumers of their rights.

A clear understanding of the power of consumer protection laws in the country is also useful. For example in Malaysia the Consumer Protection Act 1999 is a supplementary piece of legislation. There are over 30 regulations under different ministries with consumer protection elements such as the Ministry of Health, Ministry of Transport, Ministry of Energy Water and Green Technology and Ministry of Agriculture and Agro-based Industries in Malaysia. By appreciating the role and powers of the different laws related to consumer protection and the agencies, consumer associations are more effective in advocating for better consumer protection with the right agency. In Algeria, institutional framework for consumer protection depends on the services of the relevant Ministries. The Ministry of Commerce (Algerian Center for Control of Quality and Packaging), Ministry of Interior, Ministry of Justice, Ministry of Health and the Ministry of Industry to name a few.

Consumer associations with limited resources to undertake research or have limited access to information should not be taken to mean that consumers cannot form associations until such resources are available. Many movements stemmed with limited financial and human resources. Such as the work of MAMA ’86, the association of Ukrainian women protesting

26 UNCTAD. Manual on Consumer Protection. Advance Copy. 2016. Pag. 36 https://unctad.org/en/PublicationsLibrary/webditcclp2016d1.pdf 27 Idem

24 against the lack of transparency of information after the Chernobyl disaster in 1988 and their concerns for safety of the water supply.

It is worth noting that such movements often arise in response to single issues and associations cannot be expected to cope immediately with the full breadth of the consumer horizon, a scope which even the best resourced organizations have difficulty in covering.In 2006-2007, the Association of Energy Consumers in Cameroon, Réseau associatif des consommateurs de l’énergie (RACE), protested against the lack of access to electricity supply despite reassurances that were given when a concession was granted to supply power to the aluminum smelting industry28.

28 UNCTAD. Manual on Consumer Protection. Advance Copy. Pag. 36. https://unctad.org/en/PublicationsLibrary/webditcclp2016d1.pdf

3. Consumer Associations Operating Model

The nature and structure of the consumer associations has a bearing on the capacity of these associations to influence consumer protection policies, implementation and enforcement. Issues dealt with by consumer associations are influenced by a country’s level of development, education, security and access to basic infrastructures. In Tunisia, the consumer organization has developed a tripartite relationship There is no internationally accepted definition of between itself, the ministry in charge of consumer associations or organisations. However as with water, and the water utility company. all forms of establishment – government or non- This alliance has developed a government the principles of legitimacy, capacity and consumer education program and power applies. methodology to educate consumers on such issues as water wastage - Countries like India characterize consumer associations which is of primary importance in in the relevant laws. In Malaysia consumer associations Tunisia as it is a desert country. are treated as non-government organisations and are governed by the Registrar of Societies Act 1966 Box 2: Tunisia's tripartite alliance for consumer education The consumer associations should review their roles and responsibilities in order to stay relevant to their stakeholders (consumers, government agencies and businesses).

Structured organisation with systematic and professional approach increases trust in the consumer associations by consumers and other stakeholders.

Table 3: Key considerations for the development of operating model of consumer associations

Considerations How ?

Identify issues of immediate • Interview members of community interests to consumers • Complaints records • Media reports • Incident reports (e.g.: hospitals) • Are there other community based organisations or individuals in the community or country addressing similar issues?. Small or new consumer associations benefit from coalition in terms of outreach, human resources and financial resources.

Stakeholder analysis • Who are those affected negatively by the issues and can they seek redress or easily resolve any disputes resulting from the issues they face? • Who contribute or perpetuate the issues? • Who has the control over the issues (directly and indirectly)? • How to engage with each stakeholder?

Approach and structure • Collaborate with existing networks or associations or establish new one or expand scope • Stakeholder engagement methods: forum, workshop, focus group, interviews, surveys, consultation etc. • Documentation, record keeping and reporting needs • Communication and visibility – press conference, publication, collaterals (flyers, brochures) talks, announcements, community/ village forums, etc.

Relevant laws and • Laws governing establishment of consumer association regulations • Government policies on engaging with consumer associations (or civil / community based organization) • Laws, policies and strategies related to the specific consumer issues – redress, fair trade practices, dispute resolution,

Resources • Access to issue experts : ex-industry personnel, researchers, university researchers, • Human resource needs: qualifications, skills, experience, etc. • Equipment and space • Funding: government grants, membership subscription, sales, etc. • There are also incidents beyond your control which might hamper your efforts to address consumer issues in your area or country – political climate, non-inclusive policies by neighbouring countries or trading nations and so on.

General operating model of consumer associations is converting technical, public (market) and policy inputs into socio-economic outputs which is needed by beneficiaries (customers).

Inputs: Socia-Economic

•Policy Outputs: •Market issues Consumer •Policies (public/consumers) Associations •Campaigns •Technical •Education programme •Advocacy

Inputs:

•Funding

Figure 7 : Outline of Consumer Association Operating Model

This section provides general guidance for an effective operation of a consumer association. Every consumer association is unique. In general, an effective operating model is determined by the following factors:

• Governance, system o governance system need to ensure that the The Malaysian Association of consumer association is independent, transparent Standards Users started with one and accountable in its operation. employee in 2005 and board members who did not draw any form o usually a board or council oversees the operations of allowance or income from the and financials of a consumer association. The board association. Membership collection or council operate at a strategic level, providing was less than RM 1000.00 barely directions and high level planning. enough to cover utilities and rental, much less salary. Today it has o the board or council consists of panels who are secured grants from various sources independent of the consumers associations day to to allow it to operate to serve day operations and does not draw salary or income interests of consumers in terms for from the consumer association and are apolitical. product safety.

• Human resource and infrastructure Box 3 : Malaysia - example of consumer o people who work for consumer associations are association with challenges on membership collection usually driven by passion to contribute to society or their community. Young people in urban areas engage in volunteerism or seek internship at consumer associations. Those who start a consumer association may have done so in their spare time and work without salary until such time the consumer associations secure grants from either government agencies, donors or development organisations.

o As the organization grows top management of the association needs to invest time and resources in capacity building, strategic planning and sound management practices to encourage the right people to work with the association. A consumer association like many non-profit and community based organisation is not really a dream job for graduates or people with technical background like engineers and scientists. People with competition and consumer law background may find the work of consumer association to their liking. • Income and expenditure (financial) o income should be able to cover operating costs of the association. o independently audited accounts and financial statement is important aspect of good governance and is often requested by potential donors.

• Background to the consumer association o Structure o Governance • Key Issues • Stakeholder analysis • Association goals related to key Issues • Approaches and Considerations: Key activities • Resource Requirements: o Human o Methods o Materials and Equipment • Risk analysis and mitigation • Budget and fund raising • Visibility and communication • Monitoring and evaluation and continuous improvement

Box : Basic Outline of an Operating Model

4. Collaborations Between Consumer Associations and Competition and Consumer Protection Institutions

4.1. Pre-requisites for Effective Collaboration

In order to facilitate collaboration, certain pre-conditions need to exist:

i. Laws and infrastructure related to consumer protection

a. Leading consumer agencies

b. Other agencies with consumer protection roles

ii. Policy calling for participation of consumer representatives

iii. System to collect consumer feedback, questions and complaints

iv. Laws or policies governing establishment of consumer groups, associations

4.1.1. Laws and infrastructure related to consumer protection

The MENA region countries as with many countries generally have one leading consumer affairs or consumer protection agency with several sectoral consumer protection roles by other agencies. Therefore, there is no one-stop solution provider for consumer issues. In such cases there is tendency for these agencies to work in silos (on their own) with limited integrated approach to consumer protection. This leaves many gray areas where existing laws and policies does not provide guidance on consumer protection.

Consumer associations who want to improve and strengthen consumer protection in the region should reflect on the existing national situation such as the legal system and infrastructure on consumer protection.

Based on the UNGCP, consumer protection and competition agencies should look at the following elements of consumer protection (A detailed description can be obtained from the UNGCP and the UNCGP Manual).

Policy and supporting activities:

a. Availability of policies to govern businesses and enforcement agencies.- Policies to promote fair competition including for state owned enterprises and provisions for consumers to make informed purchasing, use and disposal decisions. b. Adoption of measures to safeguard safety of products for intended use and foreseeable use. c. Availability and access to redress mechanism with legal advice and representation for consumers. d. Availability of standards development and related activities to support assurance of product and services quality and safety. That these are aligned with international practices guided by WTO agreement. e. Access to basic goods and services (including utilities). f. Access to consumer education through appropriate channels, language and platforms g. Availability of policies and support initiatives to promote sustainable consumption, eliminating or minimizing use of harmful substances and materials and pollution prevention. h. Availability of policies or initiatives to protect consumers in electronic commerce, protection of privacy and personal data. i. Access to and promotion of fair financial services and availability of policies to protect consumers from unfair advantage of the finance and banking sector businesses. j. Availability of measures to protect consumers in specific area: food, water, pharmaceutical, energy, utility and tourism (based on international best practices and standards). k. Access to knowledge, technical cooperation and capacity building. l. All engagements and collaborations are guided by mutually agree terms and conditions or reference. m. Determine available resources to support the different mode of collaborations.-some consumer associations have to travel great distance to government administrative centers to attend or take part in meetings. This often results in limited consumer participation in policy meetings as they have limited funding and time).

Consumer protection agencies should be part of (at least) a regional level information exchange, forum or network on consumer protection such as: the ASEAN Committee on Consumer Protection or ACCP or the Annual African Consumer Protection Dialogue Conference or Organization of American States (OAS) Consumer Safety and Health Network.

4.1.2. Policy calling for participation of consumer representatives

An open environment for policy decisions (especially technical ones) should be fostered by the consumer protection authorities.

Compliance policies are not necessarily meant to be popular, but to ensure their effectiveness they should be supported from various sectors. 29

Consumer protection policies and laws should encourage multi-stakeholder engagement.

Box 4 : Algeria – Consumer Representation in the law

Articles 21 to 24 of Law No. 09-03) in Algeria indicates that the consumer protection association plays a key role in promoting national production, supporting consumption and protecting the health, safety and interest of consumers / citizens. There about 67 consumer associations in Algeria (as of February 2018) of which 6 are national consumer protection associations and the rest local (district / provincial level). As part of the support to consumer protection associations, the public authorities allocate financial endowments. This is allocated to the association to support activities of the associations in accordance with a program contract established between the two parties (government agencies and the associations). These associations are governed by a legal framework: Article 54 of the constitution states: "The right to create associations is guaranteed"

Once the foundation of consumer protection (laws) are in place a statutory provision for an advisory or coordinating committee to advise on matters arising from the administration of these laws should be established. This body should determine policy matters, and various ministries, industries, consumers, NGOs and academia should be represented. Ideally the advisory committee should report to the minister concerned and in most cases these reports should be published.

Where an advisory committee does not exist, industry and consumer views should be ensured through regulations. Before a major policy change, prescription or amendment of product or services standards are made, the industry and consumers have the opportunity to comment and provide additional data on the subject matter. This arrangement optimizes resource utilization and better satisfies consumer concerns as well as industry needs. Thus, compliance improves and consumer protection and satisfaction are enhanced30.

4.1.3. System to collect consumer feedback, questions and complaints

If consumer protection law exists there should be mechanisms in place to gather consumer complaints related to products or services. A toll-free line, hot line, online complaints gathering system or a dispute resolution division are examples that such systems exist.

29 R.K. Malik. Integrating consumers and industry in food control. In: Food, Nutrition and Agriculture - 8/9 - Consumer participation in food control. http://www.fao.org/docrep/V2890T/v2890t02.htm#consumer%20and%20industry%20involvement

30 Idem.

4.1.4. Laws or policies governing establishment of consumer groups, associations

The national consumer associations should be established according to national laws and regulations or part of a formal committee (or council) in order to have legitimacy in its set up and work. Activities of consumer associations should promote and protect consumer rights, provide education and benefit consumers as a whole.

Care should be taken to ensure that the association is not an industry organization in disguise or a professional organization (e.g. an organization of doctors or lawyers). If it is not possible to accommodate all the groups into the process easily, then each group should be invited to choose a representative whom it feels can best represent the diverse interests31.

In the case of Algeria there are about 50 consumer associations registered with Ministry of Commerce. They range from representing consumers in the health sector to environment and sustainable consumption. Thus, choosing the right consumer representatives according to the issue is important to ensure successful outcomes in the interests of consumers in the relevant sector.

The consumer associations could strengthen their scientific expertise through association with institutes (universities and research houses) specializing in environment, consumer laws, food safety/science, energy, climate change and sustainable consumption, etc.

4.2. Modes and Approaches for Collaborations

Consumer associations should establish purpose or objectives of its collaboration with consumer protection and competition agencies or those with similar roles. Typically, the objectives would be:

• increase understanding of the likely impact of consumer laws and policies on consumers; • increase understanding of legal requirements; • bring consumers’ concerns to the attention of policy makers • determine credibility of labeling, quality or certification marks and claims; • to provide inputs to any policy making decisions or implementation • develop content for consumer information or education materials and programmes • settle disputes / manage grievances (complaints from consumers)

Following are approaches to collaboration according to levels of engagement:

31 R. Macfarlane. The consumer voice in food safety. In: Food, Nutrition and Agriculture - 8/9 - Consumer participation in food control. http://www.fao.org/docrep/V2890T/v2890t08.htm

Consumer associations can use the following approaches (based on expertise, availability of credible data and resources) to record their positions in relation to policies and decision making:

- Position papers, working papers or memorandum (these can be distributed to all relevant ministries – where there exists multiple laws for a particular consumer product or service sector). - Focus group discussions and reports. - Multi-stakeholder workshops and reports: if the product or services category involves more than one regulator. - Survey and reports. - Analysis of complaints received for a particular consumer product or service sector (if the association handles consumer complaints).

The role of consumers associations is particularly vital for proper risk management. The problem and its proposed solution should be thoroughly examined. Objective presentation and discussion of the facts with regard to (but not limited to):

- industry and trade practices, - potential hazards to consumers, - risk assessment, - socio-cultural issues - environmental issues and - economic impact 32

4.2.1. Consumer Awareness and Education

Consumers benefit from wider dissemination of information in an appropriate form on subjects such as product safety incidences, accident reports and poisonings; incidence of food, cosmetic or medicine adulterations, counterfeit products, and the resultant economic losses, privacy and personal data protection, labeling and health hazards from street food vending etc.

Figure 8 : Getting Consumer inputs (WB report on Consumer Representation and Regulations)

32 R.K. Malik. Integrating consumers and industry in food control. In: Food, Nutrition and Agriculture - 8/9 - Consumer participation in food control. http://www.fao.org/docrep/V2890T/v2890t02.htm#consumer%20and%20industry%20involvement

Consumer protection agencies and sectoral agencies with consumer protection roles should expand and NGOs work together with Consumer strengthen their communication network. The network Protection Agency of Egypt, in should include consumers and use all current forums partnership with the Global Environment within the agency or outside for proper dissemination of Facility GEFUNDP Energy Efficiency Project to raise public awareness of information relating to problems or issues related to sustainable energy and misleading consumer products or services and educating and advertisements of disqualified led empowering consumers. lamps.

Flexible and informal approach is mostly used to reach out to the poor or rural consumers. Consumer Box 4 : Egyptian NGO collaboration on Energy associations in collaboration with the relevant agencies Efficiency project can tailor their awareness campaigns according to whether the poor are located in rural or urban areas.

Consumer associations in collaboration with the relevant agencies usually apply the following approaches (often in combination and at varying degree) for expected outcome:

- Public outreach – talks, mini workshops, nationwide young consumer education (annual) programmes; competitions and community level projects. - Social Media campaign. - Publications – infomercials, brief flyers, handbooks, guides, school curriculum. - Briefing paper – newsletters on consumer issues. - Testing and test reports. - Media or press conferences. - Surveys and polling.

Content for the publications and scope of survey if needed can be determined in consultation with the relevant agencies or experts to ensure that it provides accurate and unbiased information to the agency and for consumers to make informed choice.

4.3. Resource Barriers: 4.3.1. Funding:

As described above, major consumer groups in the industrialized world have used testing of products and magazines as their income source. Consumers in these economies usually pay to subscribe the magazine. However, it may not always be possible for groups to generate enough income, especially if they are representing the poorer sections of society. 33

To carry out activities in collaboration with other stakeholders or on its own, consumer associations often face constraints due to funding. This constraint is perennial with both government and non-government organisations.

Figure 9 : Example of Comparative Testing and Advisory Magazine (from CHOICE, Australia - left; and VOICE, India - right)

33 R. Macfarlane. The consumer voice in food safety. In: Food, Nutrition and Agriculture - 8/9 - Consumer participation in food control. 1993. http://www.fao.org/docrep/V2890T/v2890t08.htm

Under limited funding resources consumer associations or representatives should resort to analytical and writing skills. Desktop researches are helpful if national data or information is readily available or at least reported by the media.

The national consumer association should seek to be part of a regional or international network of consumer associations or civil society groups such as Consumers International, among others. These alliances could in several cases present opportunities to apply for project funding, access to expertise who often offer valuable advice on a specific subject matter and access to essential capacity building opportunities.

4.3.2. Human / Staff: To address challenges associated with limited human resources especially for technical issues – the consumer associations can engage assistance of universities or professional associations for ‘pro bono’ services – for example with lawyers and doctors.

Consumer associations should work with their national consumer protection and competition authorities to access capacity building programmes organized by the UNCTAD MENA Programme Regional Training Centres for Competition Law and Policy based in Tunis, Tunisia. The Regional Training Centre was launched in November 2016 and provides training, courses and support information exchange in Arabic and French.

4.3.3. Equipment / Materials:

When printing and communication equipment are limited and not accessible there are low cost technologies which can deliver relatively effective results. Satellite phones and community centres, ‘runners’ and loudspeakers at bazaars and marketplaces could get messages out to general public or gather feedbacks and concerns.

In terms of language and literacy, a variety of modes of communication must be used, tailored to the community. Even in highly literate societies, there is a need to recognize that the language of the specialist is not easily understandable to a wide range of people. 34

Availability of information in the language of the community and of minorities living in the community is important. Use of graphics (in low literacy communities) has worked well for organisations such as the WHO and the UN in communicating prevention measures for diseases such as the Guinea Worm Disease in Africa.

Consumer protection agencies and local authorities support could be sought to provide assistance in terms of venue, food and beverages and resources persons (expertise).

Association Name Programme / Project:

Date:

34 R. Macfarlane. The consumer voice in food safety. In: Food, Nutrition and Agriculture - 8/9 - Consumer participation in food control http://www.fao.org/docrep/V2890T/v2890t08.htm

Objectives of Possible Mode Content, Human Resources Cost and Pre-requisite Collaboration Materials Funding (for effectiveness) increase understanding of Conventional Draft copy of Knowledge of the Travel, the likely impact of correspondence policy or laws, policies and laws tokens (for consumer laws and regulations; and technical experts, policies on consumers; comments and implications (if part-timers, positions any); volunteers Meetings, focus groups, Could be group of etc), utilities, workshops and multi-disciplinary Sources – consultations consumer already representatives - provided by need not be agencies; fulltime staff. part of larger project funding or operational grants , donations bring consumers’ concerns Focus group, Policy paper, Survey, volunteers, Travel, to the attention of policy interview survey report, social researchers tokens (for makers survey complaints or experts, incidence part-timers, analysis report volunteers etc), utilities, Sources – Laws or policy already call for provided by consumer agencies; representation part of and agencies larger implement this. project If possible – funding or travel operational allowances grants , which will go a donations long way. increase understanding of Collaterals – brochures, Importance of Legal background Similar to legal requirements; flyers these experts and above Workshops requirements volunteers / staff and risk of non- for dissemination.

compliance Media personnel. determine credibility of Market surveillance, Surveillance Knowledge of the Similar to labeling, quality or consumer complaints report, policies and laws above certification marks and complaints on labeling claims; analysis report requirements to provide inputs to any Meetings, focus groups, Draft copy of Knowledge of the Similar to policy making decisions or workshops and policy or laws, policies and laws above implementation consultations regulations; and technical comments and implications positions develop content for Focus groups, Easy to knowledge of the Similar to consumer information or workshops and understand by policies, laws and above education materials and consultations target group technical programmes with implications, appropriate knowledge of graphics and adult learning format principles. settle disputes / manage community centre, Complaints knowledge of the Similar to grievances (complaints forums, interviews, analysis report policies, laws, above from consumers) survey, complaints some customer centre / hotline/online service experience / skills

Consumer organisations can assist or cooperate with consumer protection and competition agencies in advancing consumers’ economic interests via several methods and approaches as outlined in the following table:

Table 4 : Methods and approaches collaboration with consumer protection agencies according to consumer interests

Consumer Collaboration and Responsibilities and Roles Interests Partnership approaches Consumer Government Traders Organisation Agencies

Informed Consumer associations Provide complaints - Can also have - Ensure that choice which provide dispute handling (alternative specific or information resolution services can dispute resolution - general dispute provided are feedback or report to ADR) services. resolution facility, easily the relevant agencies online complaints understood and on the extent of Help consumers handling; accurate / problems associated identify what is - Laws related to impartial. with lack of or limited correct information minimum - Claims made on information to and differentiating requirements for products and consumers to make these from labeling and services are informed choice: for inaccurate or false other consumer guided by laws example, absence of information. product and of the country expiry date, absence services labeling and or illegible registration information. international or approval number on - Funding for the best practices cosmetic or operation of the - Assist in pharmaceutical ADR by consumer education and products and associations awareness language used in the - Assist in education materials assembly and and awareness content instruction manual materials content development cannot be understood. development - Platform to exchange information and analysis of the complaints received as guidance for the review of consumer protection policies and laws.

Consumer Collaboration and Responsibilities and Roles Interests Partnership approaches Consumer Government Traders Organisation Agencies

Quality and Consultations with Get involved in Based on good - Assist in Standards consumer associations national, regional standardization education and on new area of and international practices – awareness standards standards government materials development, review development. agencies MUST content and publication of make provisions to development standards. Based on consumer engage and behavior and involve consumer Consultations on expectations – raise organisations in weights and measures, issues of concerned standards unit pricing and non- to the relevant development at compliance. agencies and traders national level and if (trade / industry resources permit at sector associations) regional and international level. Educate consumers / general public about Government the role of agencies can certification marks engage consumer and testing etc. organizations to obtain information Seek to link with about how international consumers interpret standards labels and test organisations such as marks, safety the UN ECE, ISO, IEC incidents and and Codex through performance of the relevant National products and standard bodies and services. representatives. Assist in education and awareness materials content development

Consumer Collaboration and Responsibilities and Roles Interests Partnership approaches Consumer Government Traders Organisation Agencies

Complaints Establish consumer Establish consumer Ensure that there handling and complaints facilities – complaints facilities – are effective, dispute affordable and affordable and responsive, resolution accessible accessible. affordable and easily accessible Studies on consumers’ Initiate studies on complains handling expectations and consumer needs system or dispute dissatisfaction in contingent upon resolution facility. products and services availability of resources.

Weights and Market surveillance Consumer Ensure availability Consultation with Measures and complaints from organisations and efficiency of officials on the (WM) consumers are forms of channel WM related WM verification market issues feedback to the complaints to the (calibration) related to WM. relevant government relevant authorities facilities – physical, agencies on the and provide updates chemical, etc). Need to review effectiveness of the on anticipate impact existing WM weights and measures of latest technologies Clear packaging policies and laws. act in the country. which include or and labeling laws introduce new forms and policies WM laws should also of commercial governing business keep pace with latest measurement to business and technology systems. business to developments such as consumers standard commercial measurement for measurement broadband speed and systems. unit pricing for call time and mobile data. Assist in education and awareness materials content development.

Table 5 : Summary Checklist for Consumer Associations on Effective Collaboration Between Consumer Associations and Consumer Protection and Competition Agencies

Logical Steps Descriptions Status

Pre-conditions - Understand consumer issues in your area / community o Basic needs, product / services safety, information, choice, redress, environment and health, consumer education, complaints / grievance procedure o Who are your networks : researches, media, local community leaders, student bodies, village heads etc? - Consumer protection laws and policies in your country o Any avenue for participation? o Channels of communication? o Redress and complaints handling mechanism? - Understand the UNGCP

Determine objective - Increase understanding of consumer laws and of collaboration policies. - Increase understanding of legal requirements. - Bring consumers’ concerns to the attention of policy makers. - Determine credibility of labeling, quality or certification marks, compliance and claims. - Io provide inputs to any policy making decisions or implementation. - Develop content and approach for consumer information or education materials and programmes. - Settle disputes / manage grievances (complaints from consumers).

Develop / determine - Research, test or survey report. approach / mode - Focus group, consultations, workshops. - Meeting. - Press conference or media release. - Outreach (public) – talks, mini workshops, nationwide young consumer education (annual) programmes.competitions; community level projects. - Social media campaign. - Publications – infomercials, brief flyers, handbooks, guides, school curriculum. - Briefing papers. - Newsletters on consumer issues.

Determine resource - Human resources. requirements - Funding. - Materials and equipment.

Determine - Did you meet the objectives of the collaboration and effectiveness and the actions?. improve where needed

5. New Challenges for Consumers Associations in the Digital Era The era on high speed internet, everything internet, social media and collaborative or shared economy, have increased role of individuals driving changes without consumer associations’ involvement. Dave Caroll the Canadian musician’s 2009 song on YouTube about how United Airlines broke his guitar and didn’t want to pay for it resulted in the airline’s stock taking a plunge.

Small consumer groups can gather widespread consumer interest groups to support each other in their efforts to lobby for better corporate behavior or international recognition for consumer voice. The internet has increased the speed, convenience, and propensity for such coalition building.

Young consumers who are highly tech savvy can create videos or images that go viral and compel business or even governments to improve services. They compare companies’ actions against their promises and share stories of their own experiences - positive or negative. The connected world has enabled individual opinions to be shared at unprecedented scale and speed.

Consumers, consumer associations, businesses and governments spend increasing amount of resources (money and time) to manage or response to such news when these can be spent on more pressing matters.

Driverless cars, internet access to rural communities, using drones and spy toys are posing new risks to consumers physically and in terms of personal data protection, privacy and security. On the other end of the spectrum large populations of the world still do not have access to basic needs such as clean water, sanitation, safe food and healthcare.

There are many research and policy studies undertaken to respond to these changing times and new demands. Consumer associations should review its approaches to ensure that they are still relevant and versatile to accommodate new technologies and manage new risks. There are platforms where consumer associations can interact with other consumer associations (large or small) and other stakeholders such as businesses to better understand impact of latest technologies, gadgets and way of doing business or new ways to solve old problems.

In the era of shared economy, collaborative consumer protection is perhaps the approach to ensure that consumers are protected both online and offline.

The UN Sustainable Development Goals or SDGs addresses various consumer protection issues among them being:

• Road safety • Safe mobility • Sanitation and clean water • Access to energy (renewable) • Sustainable consumption and production • Waste management

Consumer associations and consumer protection agencies need to review their roles in line with evolving consumer and community needs. There are new and innovative low cost technologies and solutions to age old problems.

6. Conclusions 1. Consumers are a dispersed group that lacks expertise and resources and is unlikely to be heard by regulators. Consumers in conflict areas and countries emerging from conflicts are disoriented and inadequately represented by a fragmented set of civil society organizations with limited resources and expertise.

2. Collective consumer movement (in the form of national association or international organizations) helps to equalize that situation, it can compel corporations to improve ethical business practices. Consumer associations can also influence consumer friendly policies in uncompetitive market environment in utilities services such as water and sanitation services. Consumer associations are very much part of a larger ecosystem of consumer protection infrastructure and systems. A functional and effective consumer association makes significant and positive impact on the lives of consumers in the country and the region. Their effectiveness and the way they operate depend very much on national conditions such as consumer protection laws, culture and availability of local knowledge, researches and availability of resources.

3. Consumers associations should be supported by governments at least at the initial stages of their establishment and have in place strategies to diversify sources of funding in order for the associations to be sustainable. Moreover, Government agencies should at least ensure that policies call for and support consumer participation and involvement in policy development and implementation.

The role of an independent consumer association is still indispensable when it comes to consumer protection especially in developing countries. They give voice to the voiceless and ensure that the balance of power in business to consumer relationship is not skewed to business interests. Consumers associations should ensure that the governance mechanisms in place enhance the association’s transparency and accountability to those it represents. In fact, They need to use a combination of fund raising initiatives and methods to be able to continue serve consumers’ interests.

4. Consumer associations and consumer protection and competition authorities need to collaborate to implement consumer protection policies effectively and efficiently. In order to facilitate collaboration, certain pre-conditions need to exist: (i) laws and infrastructure related to consumer protection (agencies with consumer protection roles), (ii) policy calling for participation of consumer representatives, (iii) system to collect consumer feedback, questions and complaints, ans, (iv) laws or policies governing establishment of consumer groups.

7. Resources

7.1 About UNCTAD and MENA Competition and Consumer Protection

With the support from the Government of Sweden, UNCTAD developed this regional capacity building programme launched in 2015, which aims at contributing to regional economic integration, anti-corruption, good governance and gender equality by strengthening markets through improved competition and consumer protection policies in the Middle East and North African region.

The UNCTAD MENA programme will aim to35:

Enhance MENA countries' effective capacities to adopt and implement regional competition and consumer protection programmes. This will be accomplished through the introduction of national policies and legal frameworks and institution building. The latter includes establishing agencies for competition and consumer protection, training enforcers and engaging regional cooperation initiatives.

Help companies and business associations comply with competition and consumer protection laws and regulations. This will be done through advocacy for voluntary compliance, for integrating the informal sector into the formal economy and for eliminating unfair trade practices. There will also be workshops, and guidelines will be published on applying laws and regulations and guidelines on leniency programmes.

Assist MENA countries in establishing an effective dialogue among policymakers for coherence between competition, consumer and other public policies. This will include assistance in adopting competition neutrality frameworks and in implementing Regulatory Impact Analyses, to avoid unnecessary burdens to competition.

7.2 Excerpts from UNGCP 2016 on Consumer Organisation and Groups

21. Member States should intensify their efforts to prevent practices which are damaging to the economic interests of consumers through ensuring that manufacturers, distributors and others involved in the provision of goods and services adhere to established laws and mandatory standards. Consumer organizations should be encouraged to monitor adverse practices, such as the adulteration of foods, false or misleading claims in marketing and service frauds.

30. Member States, in close collaboration with manufacturers, distributors and consumer organizations, should take measures regarding misleading environmental claims or information in advertising and other marketing activities. The development of

35 UNCTAD PRESS CENTER “COMPAL GLOBAL: support to MENA countries Wednesday 23rd April 2014 - 13:45-14:30 Palmeraie Golf Palace, Marrakesh, Morocco Side-event at the 14th ICN Annual Conference” https://unctad.org/fr/pages/newsdetails.aspx?OriginalVersionID=738&Sitemap_x0020_Taxonomy=International%20Tr ade%20and%20Commodities

46 appropriate advertising codes and standards for the regulation and verification of environmental claims should be encouraged.

31. Member States should, within their own national context, encourage the formulation and implementation by businesses, in cooperation with consumer organizations, of codes of marketing and other business practices to ensure adequate consumer protection. Voluntary agreements may also be established jointly by businesses, consumer organizations and other interested parties. These codes should receive adequate publicity.

41. Member States should cooperate with businesses and consumer groups in furthering consumer and business understanding of how to avoid disputes, of dispute resolution and redress mechanisms available to consumers and of where consumers can file complaints.

42. Member States should develop or encourage the development of general consumer education and information programmes, including information on the environmental impacts of consumer choices and behaviour and the possible implications, including benefits and costs, of changes in consumption, bearing in mind the cultural traditions of the people concerned. The aim of such programmes should be to enable people to act as discriminating consumers, capable of making an informed choice of goods and services, and conscious of their rights and responsibilities. In developing such programmes, special attention should be given to the needs of vulnerable and disadvantaged consumers, in both rural and urban areas, including low-income consumers and those with low or non-existent literacy levels. Consumer groups, business and other relevant organizations of civil society should be involved in these educational efforts.

45. Member States should encourage consumer organizations and other interested groups, including the media, to undertake education and information programmes, including on the environmental impacts of consumption patterns and on the possible implications, including benefits and costs, of changes in consumption, particularly for the benefit of low-income consumer groups in rural and urban areas.

92. Member States and international organizations, as appropriate, should promote and facilitate capacity-building in the area of sustainable consumption, particularly in developing countries and countries with economies in transition. In particular, Member States should also facilitate cooperation among consumer groups and other relevant organizations of civil society, with the aim of strengthening capacity in this area.

References:

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