report-position-of-consumers-summary
Dieses Dokument ist Teil der Anfrage „Gutachten des Sachverständigenrats für Verbraucherfragen“
SUMMARY AND RECOMMENDATIONS 3
account of the COVID-19 pandemic. Of those, just
under two thirds believe that their consumption 2 The position of consumers
patterns are more sustainable than before the pan-
demic. Of this group, around 80 % state that they In view of the structures and institutions of consum-
will also uphold these consumption patterns after er policy and the economic and health related con-
the pandemic has ended. sumer protections which exist in Germany, the SVRV
does not consider the position of consumers to be of
• Since the beginning of the pandemic, attitudes in fundamental concern. At the same time, consumers’
Germany towards the digital transformation have concerns are diverse and the influencing factors in the
also changed markedly. Whilst in 2018 only 44 % different fields of consumption are heterogeneous. As
of respondents in a survey believed that the digital a consequence, despite the generally sound framework
transformation will create opportunities for socie- conditions, consumers and consumer associations and
ty, this figure rose to 49 % in the first month of the organisations are voicing complaints in a number of
lockdown (March 2020) and to 57 % in the second areas. These must be taken seriously, assessed and,
month of the lockdown (April 2020). The restrictions where necessary, addressed.
imposed by the pandemic have shown that the dig-
ital world can also serve as a safeguard against For example, new technologies in the digital sector,
risks by ensuring access to relevant areas of life which quickly become widespread, often pose chal-
and associated goods and services for consum- lenges to consumers. An appropriate framework to
ers, even under difficult conditions. For example, meet these challenges needs to be established. How-
a lockdown in which many people have to switch to ever, this can only be done gradually. Malnutrition is
working from home would not have been possible a structural problem which causes problems in the
or would have had serious negative consequences food sector. In the housing and mobility sector, anoth-
in the absence of digitisation. er structural problem is that many people would like
to live quietly and affordably – a wish that cannot be
Many subject areas on which this report focuses are easily fulfilled in cities, resulting in many people living
and have been significantly affected by the COVID-19 in the outskirts of cities or in the countryside. The re-
pandemic. However, it is largely unclear which econom- sulting divergence between work, housing and leisure
ic challenges and problems for consumers will arise gives rise to mobility pressures and possibly a perma-
from the COVID-19 pandemic in future. nent decline in life satisfaction. Consumers who wish
to consume more sustainably also encounter structural
problems in that the relevant products cannot be easily
identified or are not readily available.
4 2021 REPORT ON THE POSITION OF CONSUMERS
policy. Beyond consumer policy in the narrower sense,
3 Results specific to the social housing is, and will remain, necessary in the
fields of consumption long term in order to provide suitable and affordable
housing. The State should fulfil its responsibility to cre-
ate the framework conditions necessary for continued
3.1 Housing sector: Peace house building, in particular in the lower and medium
and quiet and affordability price range.
are central factors for “good Against this background, the SVRV makes the following
housing” in Germany recommendations as regards the further development
of the housing sector:
People in Germany spend on average just over a third of
their consumer budget on housing, and the associated Recommendation 1: Compile statistics on homeless
housing satisfaction is high. This is a result of, amongst people and people in institutional care facilities
other things, the differentiated regulatory approach and accommodation centres regularly and across
of German tenancy law. Problems arise in particular Germany
upstream, namely in the form of information related
problems when looking for a flat or a house, and when The number and living conditions of homeless people
signing a lease. and people living in institutional care facilities and ac-
commodation centres should be compiled statistical-
Although no precise figures are available, it can be as- ly, reported and discussed across Germany. The SVRV
sumed that around one million German households (a welcomes the Homeless Reporting Act (Wohnungs
number which is equivalent to around two million peo- losenberichterstattungsgesetz), which provides sta-
ple) are currently unable to meet the costs of heating tistics on homeless people for the first time for 2022.
and can therefore be classified as living “in energy pov- However, the problem of homelessness must not be
erty”. In this respect, it is significant that an analysis set merely quantified but discussed further and actually
out in this report shows that CO2 pricing, which is im- addressed.
portant for environmental policy reasons, can be imple-
mented in such a way that consumers experience, on Recommendation 2: Expand the Housing Benefit and
average, little or no additional financial burden. How- Rent Report (Wohngeld- und Mietenbericht) to create
ever, an easing of the financial burden on average does a more comprehensive “Housing Report”
not mean that CO2 pricing could not lead to an undesir-
able financial burden on individual groups. This must The Federal Government’s Housing Benefit and Rent Re-
be borne in mind and, where necessary, addressed in port should be supplemented by an appropriate report on
a targeted manner. the situation of owners, in particular owner-occupiers,
people in institutional care facilities and accommoda-
In the housing sector, there is only selective pressure tion centres as well as homeless people. Accordingly,
for consumer policy action that would benefit relative- this could then be published as a “Housing Report” to
ly few consumers compared to the overall population. reflect the proposed extension. In addition, certain for-
However, the need for action goes beyond conventional ward-looking key themes relating to the housing sector
instruments of consumer policy, in particular in areas should be selected – such as, for example, affordability
most important to those questioned, namely peace and in cities, accessibility, digitisation and commuting – and
quiet and affordability. On a small scale, peace and qui- core indicators should be included and discussed in the
et can be achieved by installing soundproof windows. report. In principle, the ministry in charge should as-
On a large scale, however, infrastructure measures sess whether the Housing Report should continue to be
that extend into transport policy are required (“traffic drawn up as a government report or by an independent
calming”). In addition, where housing is insufficiently expert committee or a council of experts (see also the
available, in particular in cities, the criterion of afforda- final recommendation on expanding consumer research
bility obviously extends into the broader field of housing at the end of the summary).
SUMMARY AND RECOMMENDATIONS 5
Recommendation 3: Take greater account of Recommendation 6: Monitor disconnections of
the subjective factors of good housing electricity supply and “energy poverty” and better
understand cases of hardship
The SVRV recommends that greater account be taken
of subjective factors of good housing overall. Questions There are many reasons for threats of disconnection of
on satisfaction with housing, for example in the German electricity supply. They range from incorrect re-registra-
Socio Economic Panel (SOEP), whose data is already tion of electricity customers upon moving house, through
used in the official Housing Benefit and Rent Report forgotten payments, to actual financial difficulties. There
(Wohngeld- und Mietenbericht) and the Poverty and is potential here for improved conflict management to
Wealth Report (Armuts- und Reichtumsbericht), could reduce further the number of disproportionate discon-
provide a starting point. The answers in a survey con- nections and threats of disconnection. Electricity pro-
ducted on behalf of the SVRV on the subjective housing viders should be required to use disconnection threats
cost burden and the appropriateness of housing costs more moderately and instead rely on the milder instru-
could further enrich the debate on subjective factors of ment of demand notices. The correct degree of sanction-
good housing. Corresponding empirical studies could ing electricity customers must be maintained, in particu-
be an important task for specialised consumer re- lar because an analysis by the SVRV shows that the fault
search institutions. does not always lie with the customer but may be with
the electricity provider’s system. Developments in cases
Recommendation 4: Record the housing cost burden of disconnection threats and announcements and actual
appropriately disconnections, and in the reasons for them, should be
statistically monitored on a permanent basis.
Since the housing cost burden (the ratio of housing
cost to household income) is criticised for being more Recommendation 7: Ensure peace and quiet and
akin to a mere empirical observation (with no theoret- reduce mobility pressure
ical basis) and, in certain cases, is unable to draw a
clear line between households with potentially existen- The ability to experience peace and quiet is an important
tial problems and households with “luxury problems”, housing objective for many people. There are also health
critical reflection on the housing cost burden should be reasons for having effective noise control. In particular,
encouraged. The SVRV will take a position on this issue the reduction in traffic noise and noise control by making
in a separate publication. changes to the house itself can be shaped by policy in
a straightforward manner, for example through relevant
Recommendation 5: Bear in mind peaks in measures in housing building policy and a transport pol-
the housing cost burden and address them icy to reduce traffic noise. It is true that these measures
in a targeted manner are not – like social housing referred to above – among
the conventional subjects of consumer protection. None-
People who are possibly in particular financial difficulty theless, the SVRV recommends as follows:
should be examined more closely, also with regard to
the housing cost burden, in order to identify and evalu- 1. Two goals can be achieved at once with increased
ate the need for support more effectively. Appropriate installation of modern windows, namely the re-
measures to reduce the housing cost burden can range duction of noise and an improvement of thermal
from information on debt counselling to housing benefit insulation. This could be realized, for example, as
and references to social housing provision. part of building renovation or energy-efficiency ren-
ovation. In order to design good policy measures, it
would be necessary to assess whether the relevant
legislation and existing technical guidelines, such
as DIN 4109 (“noise control in buildings”), are im-
plemented properly, and whether a sufficient num-
ber of people benefit from “enhanced noise control”
(Supplement 2 of DIN 4109).
6 2021 REPORT ON THE POSITION OF CONSUMERS
2. It should be assessed whether energy-related mod- Mobility must be regarded as an essential service of
ernisation, such as the installation of sound and general interest, since it is necessary to participate in
heat insulating windows, should be given priority society with equality of opportunity and to satisfy basic
over other modernisation measures and different needs such as work, education, medical care or food
levy rates should therefore be set out in tenancy shopping. Against this background, consumer policy
law. In the medium term, however, the aim of lim- should ensure that supply gaps in public transport are
iting rent increases due to modernisation to the removed. This includes improving access to public trans-
amount of savings from modernisation measures port and enhancing its attractiveness (reliability, comfort
should be pursued. In this way, particularly house- and safety). In metropolitan areas, the focus must be on
holds with low incomes – and possibly with windows redistributing public space in favour of environmental-
which are disproportionately more in need of reno- ly friendly modes of transport (walking, cycling, public
vation – are not excessively burdened. transport) and making multimodality easier for consum-
ers. The SVRV makes the following recommendations as
3. Support programmes for energy-related renova- regards the further development of this sector:
tions should be designed in a more simple manner
and also take the situation of tenants into account. Recommendation 8: Develop empirical indicators on
For example, it would be conceivable for landlords, basic services in the mobility sector
tenants and representatives of state support pro-
grammes to come together to discuss how the The debate on a successful design of mobility is ham-
objective of the renovation can best be achieved pered by the absence of any definition of “adequate”
while taking account of all the various interests in public provision of transport services. The SVRV rec-
a particular case. This would require creativity and ommends the development of empirical indicators for
flexibility. It may also make sense to grant access to evaluating basic services in the mobility sector (see
the support programme not only to landlords, who also the final recommendation on expanding consumer
in many cases do not make use of them, but also research at the end of the summary).
to tenants.
Recommendation 9: Reduce mobility pressure
3.2 Mobility sector: Ensure the The systematic use of the benefits of digitisation and
supply of public mobility and the expansion of options to work from home in profes-
sions where this is possible can make a significant con-
redistribute public space tribution to removing the division between working and
living, and thus reduce mobility pressure.
Infrastructure problems are particularly evident in the
mobility sector. Consumers in Germany are subject It would be possible to set up regional co-working spaces
to high mobility pressure. In their everyday lives, they in the countryside where employees could work close to
have to commute between their home and workplace home. Consistent and well-thought-out implementation
and also travel between shops, offices, care facilities would produce additional positive side effects which go
and leisure facilities. People with obligations of care far beyond the mobility sector. This includes the fact that
often also have to travel to nurseries, schools, and re- rural areas and towns would become more liveable again
tirement and nursing homes, etc. Consequently, mo- because people could not just live but also work well and
bility costs account for a large proportion of consumer relatively cheaply there. If more people, especially younger
expenditure. After housing costs (35 %) and food costs people, lived in rural areas again, this would have effects
(14 %), consumers spend the third largest proportion of on the location of companies which, for example, provide
their budget (14 %) on mobility. everyday goods, and it would, possibly, be worthwhile again
to provide more schools and a broader cultural offering
in these areas. Overall, the pressure on the cities and the
associated infrastructure-related challenges would be re-
duced both for the rural areas and the cities.
SUMMARY AND RECOMMENDATIONS 7
Of course, there are a host of challenges which should Recommendation 13: Renegotiate public space
be carefully monitored and resolved, in particular is-
sues of labour law (working hours, inspection rights, The policy objective of a car-orientated city should be
management rights, insurance coverage, taxes, data abandoned. The objective of environmental sustain-
protection, etc.). This also includes issues regarding ability in particular can be achieved only by shifting
where, for example, workers whose homes are not from the car to slow modes of transport (walking, cy-
large enough for working from home should work or cling) and public transport (train, urban railway, under-
who bears the additional costs of working from home. ground, trams and buses). The SVRV therefore recom-
Furthermore, digital infrastructure should be improved, mends that various measures be taken to strengthen
in particular in rural areas. slow modes of transport and public transport and shift
the overall balance between those forms of transport.
Recommendation 10: Ensure basic provision Therefore, infrastructure measures in the fields of ur-
of public transport ban development and urban and transport planning are
necessary. The SVRV notes that a fair distribution of
Adequate public transport provision should be under- public space, having regard to the needs of all road us-
stood as a service of general interest. The SVRV rec- ers, is central to the development of a people-oriented
ommends, in particular, that disused railway stations city. Against this background, the SVRV recommends
and lines be re-opened and all medium-sized towns be the institutionalisation of a national dialogue on the
connected to the rail network. Network densities and necessary conditions for developing and implementing
frequencies should be increased in rural areas and alternative, sustainable and integrative mobility con-
should not be guided by school traffic alone. Travel cepts, in particular on introducing a guiding principle
times should be reduced. National and regional plan- whereby cycling and public transport are given priority
ning should go hand in hand to take account of depend- at all levels in transport planning.
encies and effects at all levels. In order to close gaps in
public transport in particular in rural areas, transport Recommendation 14: Facilitate multimodality
companies should develop from pure bus or rail pro-
viders into integrated transport service providers with The combination of environmentally friendly modes of
a broad range of demand-orientated services. It is also transport (walking, cycling and public transport) and
important that consumers be given sufficient informa- new digital forms of mobility should be made available
tion as to what is on offer. to consumers in an uncomplicated and swift manner.
The SVRV therefore recommends the development of
Recommendation 11: Reduce mobility costs overarching platforms such as those already estab-
lished in Helsinki which take account of various means
Improvement in basic services should, at the same of transport in route planning and cover an entire trip
time, entail a reduction in mobility costs for individual with a single purchase. Consumers should be able to
consumers, primarily in the lower income groups and find their way around quickly on the ground, and “mo-
in rural areas. Price rises in public transport should bility hubs” should be set up at central locations.
be proportionate to the increase in general living costs,
particularly where no increases in provision or quality Recommendation 15: Enhance the attractiveness
are evident. of public transport
Recommendation 12: Identify and take account A central measure in shifting mobility from the car to
of disadvantaged consumer groups public transport is enhancing the attractiveness of pub-
lic transport. Consumers appreciate the comfort and
The mobility needs of low-income consumers, wom- flexibility that motorised individual transport offers
en, children, young people and families, elderly peo- them. Only through constant improvements in provi-
ple, migrants and people with (physical) disabilities sion and quality can public transport compete with the
should be recorded appropriately and given greater private car. In this context, reliability, comfort and the
consideration. feeling of safety in particular should be increased.
8 2021 REPORT ON THE POSITION OF CONSUMERS
Recommendation 16: Make cycling safer 3.3 Food sector: Enable better and
and more attractive
more targeted information and
Measures for cycling must not be among the voluntary
reduce the flood of labels
tasks of the municipalities. Instead, the Federal Gov-
ernment and the Länder should lay down the frame- In the food sector, consumers are confronted with a central
work for safe and attractive cycling and support and and complex field of consumption which entails relatively
coordinate municipal cycling policies. The National Cy- high expenditure, is an essential component of everyday
cling Plan should be developed further and contain na- life and serves to form a person’s identity and lifestyle. At
tionally binding targets and action plans. In particular, the same time, there are a confusing number of different
the German Road Traffic Regulations, other relevant goods and forms of distribution for food, which means that
laws and the range of fines would have to be adapted. many different problems have to be overcome. From the
Cycling infrastructure should be expanded, and e-bikes point of view of the consumer, the subject areas of ingre-
and pedelecs should be promoted. dients and nutrition labelling, quality labels, the (regional)
origin of food, meat consumption and the cost of food are
Recommendation 17: Increase the attractiveness particularly pertinent. In addition, migrant consumers in
of electromobility for consumers particular are often confronted with additional problems
on account of religious food requirements. Therefore, the
Increased electromobility can succeed only if there is SVRV makes the following recommendations as regards
a dense, user-friendly charging infrastructure which the further development of this sector:
lowers the overall cost of electromobility for consum-
ers and if consumers are informed of the environmen- Recommendation 19: Create confidence by means
tal advantages of electromobility as well as possible of reliable and transparent food controls
shortcomings.
In order to achieve a higher number and effectiveness
Recommendation 18: Test and use of inspections, the SVRV recommends the following
the potential of digitisation measures:
Technological solutions which make individual and pub- 1. First and foremost, more human resources are re-
lic mobility simpler, more efficient and, possibly, even quired.
more environmentally friendly, should be promoted. In
order for all consumers to benefit equally from the po- 2. The conflict of interest between promoting local busi-
tential of digitisation, improvements in general digital ness and consumer protection should be resolved by
infrastructure and in the degree of public digitisation in means of a higher, independent inspection authority.
terms of access, use and skills are required (see rec-
ommendations on the subject of the digital world). As 3. In the event of maladministration, penalties should
regards the mobility sector, the elderly population and be imposed consistently, primarily in the form of
rural areas are of particular importance. fines which cause companies such high costs that
they actually have a deterrent effect.
4. Mandatory uniform data collection and data ex-
change between the inspection authorities should
be established in order to ensure early identifica-
tion of undesirable developments and facilitate an
exchange of inspection results.
5. An obligation to publish all the results of food in-
spections should be introduced in order to strength-
en consumer confidence.
SUMMARY AND RECOMMENDATIONS 9
Recommendation 20: Improve consumer guidance – 2. The aim should be EU-wide harmonised labelling,
thin out the quality label jungle control and penalisation.
At present, consumers are overwhelmed by a “flood of 3. It should be examined how the concept of the label
labels”. Their confidence can be gained only by enforcing for regional products (“Regionalfenster”) can be
legislation on and by monitoring food labelling. There- improved, for example in relation to the minimum
fore, the SVRV recommends the following measures: proportion of regional ingredients and the definition
of the size of the region.
1. The flood of labels should be reduced by focusing
on a few concise and informative quality labels with Recommendation 22: Establish and improve
a high recognition value. consumer education in nurseries and schools
2. In order to establish legal clarity and legal certain- Since our eating habits are shaped decisively in e
arly
ty, a legal framework for quality labels should be childhood, improved consumer education makes sense
developed in line with EU law. This legal framework in particular in nurseries and schools. The SVRV rec-
should lay down compulsory minimum standards ommends that food and consumer education become
founded on scientifically based criteria and min- mandatory in an existing subject or that a new sub-
imum requirements for monitoring compliance ject be established nationwide and that the training of
with those criteria. The integration into the German teaching staff engaged in consumer education be set
National Accreditation Body and a procedure for up and promoted. The material and personal frame-
state recognition and monitoring of labels and cer- work conditions for this field of education should be
tificates and the identification of state-recognised significantly expanded and the consumer skills of
labels and certificates are necessary. school pupils should be regularly evaluated.
3. Alternatively, competing labels of companies or The compulsory school lunches in all day schools
NGOs should be permitted only if their standards can should be used for consumer education. Rules or
be proven to be above minimum statutory standards. agreements on quality (e. g. the binding introduction
of German Nutrition Society (DGE) quality standards
4. Regular communication measures should help for school meals) and the design of meal provision
raise awareness, since national labels can have and its incorporation into educational projects should
proper effect only if they are familiar to customers be adopted nationwide. Furthermore, the school meal
and understood by them. networking bodies of the Federal Government and the
Länder should be strengthened and expanded to sup-
Recommendation 21: Create clarity by clear port schools in the planning and optimisation of mass
labelling of regional foodstuffs catering.
Labelling on food products relating to their (regional) Recommendation 23: Create incentives for
origin is often opaque or even misleading. The SVRV reduced meat consumption
recommends the following measures:
Most consumers would like to continue to eat meat
1. The geographic region indicated on a label should and would thus consider any regulation restrict-
be clear and easy to understand. Therefore, the ing their meat consumption as an unwanted seri-
SVRV recommends that all producers be required ous interference in their private and everyday lives.
by law to use only the “Regionalfenster” – a volun- Therefore, instead of banning or heavily regulating
tary private label for regional products introduced meat consumption, measures which address the fun-
in 2014 – or a comparable national label for all food damental willingness of consumers significantly to
products which are advertised with reference to reduce their meat consumption will have a greater
their regional origin or whose packaging displays prospect of success. The SVRV recommends the fol-
a regional reference. lowing measures:
10 2021 REPORT ON THE POSITION OF CONSUMERS
1. One significant approach is to inform consumers
of the consequences of eating meat and other ani- 4 Current subjects of
mal products and the benefits of switching to more
plant-based food.
consumer policy:
Sustainable consumption
2. Measures to improve the provision of tasty vegan,
vegetarian or at least meat-reduced dishes as part
and the digital world
of meals consumed outside the home, such as in
canteens, school dining halls, refectories, pubs, 4.1 Sustainable consumption:
restaurants and take-aways appear practical. These
Promote awareness and
measures should target employed and retired peo-
ple along with people in education and training, since
skills, offer more sustainable
many of these consumers eat at least one meal a products and carry out
day outside their home. Therefore, the SVRV recom-
regular positioning
mends examining how the training of catering staff
can be improved in this area.
In achieving the global UN Sustainable Development
3. The development of affordable, healthy and at- Goals (“SDGs”), Goal 12 “Responsible Consumption and
tractive alternatives to meat is another important Production” plays a central role. With regard to SDG 12,
strategy for creating incentives for reduced meat companies and consumers are responsible for taking
consumption. an active part in shaping the system of production and
consumption. Consumers influence the upstream pro-
4. As a political instrument which intervenes deeply in duction of goods with their consumption decisions. For
the market, and is therefore more politically sen- example, by recycling products or their (re-)packaging
sitive, an increase in the price of goods of animal and thereby supporting a circular economy, consumers
origin is under discussion, but its suitability, social also influence the shape of the (future) use of resources
acceptability and unwanted side effects still need in production. However, this is possible only if there is
to be examined. also a supply of sustainable products.
Recommendation 24: Implement clear animal Even if consumers are offered such products, they can
welfare labelling become aware of the need for sustainable patterns of
behaviour and thus contribute to the establishment of
The Federal Government should (finally) introduce a sustainable consumption patterns only if they are well
mandatory national animal welfare label and contin- informed. Consumers must therefore have knowledge
ue to advocate for uniform mandatory labelling at EU of the process and product (“literacy”).
level. Labelling should be used to provide consumers
with transparent information about the animal welfare Against this background, this report focuses on the
performance of a particular product. An animal welfare three prerequisites for long term sustainable con-
label should have several levels, and the label criteria sumption, namely sustainable consumption aware-
should not be based on what farmers are able to do ness, sustainability skills (also sustainability literacy)
simply and cheaply but should reward significant in- and opportunity for sustainable consumption. The
creases in animal welfare. For this reason, the award empirical analyses show that awareness of sustain-
criteria for the higher levels of the label should also be able consumption and skills needed for sustainable
raised gradually over time. consumption are, in principle, anchored in German
society. Furthermore, the specific understanding of
the multidimensionality of the concept of sustainabil-
ity, that is to say the systematic integration of ecolog-
ical, social and economic aspects, is rather poor. The
skills in “assessing” information on sustainability and
“acting” sustainably also differ. In many areas, people
SUMMARY AND RECOMMENDATIONS 11
may possess the skills and willingness to consume in a Recommendation 27: Simplify and facilitate
sustainable fashion, but there is a lack of opportunities opportunities for sustainable consumption
for sustainable consumption.
The creation of opportunities for sustainable consump-
Thus, the recommendations relate to both the reduc- tion concerns the supply of and access to sustainable
tion of shortcomings and the overcoming of barriers, as products and services and the ability to identify them
well as promoting sustainability skills and awareness: easily when making consumption decisions. Policy
framework conditions and incentive structures in pro-
Recommendation 25: Raise awareness duction and consumption should be developed for the
of sustainability in all three dimensions purpose of expanding supply and improving identifia-
bility. Firstly, consumer policy should assess the legal
The sustainability awareness of the public and policy feasibility of approaches to improve consumer informa-
makers depends, amongst other things, on which sus- tion, actively drive them forward, and test them for con-
tainability strategy the Federal Government and its sumer acceptance and receptiveness in pilot projects.
ministries consider to be the guiding principle and how Secondly, it should promote sustainable product design
they develop, implement and communicate the relevant and its provision by stepping up further development
measures, programmes, action plans and legislation. of the EU Ecodesign Directive. Such a sustainable de-
Therefore, the SVRV recommends that the Federal Gov- sign directive should integrate all three dimensions of
ernment and its ministries further develop, implement sustainability and drive forward the inclusion of further
and communicate the consumer policy perspectives products in the implementation measures. Thirdly,
within the German Sustainability Strategy. This pro- regulatory and legislative measures for sustainable
cess should be guided consistently by the Sustainable consumption should be systematically examined with
Development Goals (SDGs) of the 2030 Agenda and take regard to a socially just design.
account of the ecological, social and economic dimen-
sions of sustainability. It is further recommended that Recommendation 28: Establish and
the public be made aware of the connection between communicate monitoring
sustainability and legislation, in particular with regard
to consumer law. Contradictory aspects of environmen- In order to record developments and changes relating
tal and consumer policies can thus be identified and to awareness, skills and the taking of opportunities for
resolved, thereby promoting sustainability. sustainable consumption systematically and over time,
the SVRV recommends that the Federal Government
Recommendation 26: Promote sustainability take measures to create structures in order to monitor
literacy through education and consumer advice these central factors.
One of the basic prerequisites for sustainable con- Consumer policy could take the survey carried out for
sumption is the ability to discern and understand the this report as a starting point for regular, scientifi-
systematic links between consumption and production cally supported monitoring in the field of sustainable
in all three dimensions of sustainability – namely the development. This should include assessing the level
ecological, social and economic dimensions – and to of awareness around sustainable consumption in its
develop sustainable options for action and be able to multidimensionality and correlating its development
experience their consequences in everyday life. There- with sustainability literacy and the taking of opportu-
fore, consumer policies should examine existing op- nities. In the course of the monitoring, the measuring
portunities and material for education in sustainable instruments and the socio-economic differentiation in
development and consumer advice as regards their the method and assessment should be validated and
potential to promote sustainable consumption skills, in developed further. The monitoring should be supple-
particular the “assessing” and “acting” dimensions of mented by further aspects (such as the measurement
sustainability literacy. Therefore, the need for updates of the action on sustainability or resource consumption)
in areas relevant to consumer (law) policies should be and used for the purpose of evidence-based evaluation
identified to initiate (further) development of corre- of measures. Finally, the findings from the monitoring
sponding (innovative) education and guidance. should be made continuously available to the key stake-
12 2021 REPORT ON THE POSITION OF CONSUMERS
holders in politics, business and organised civil society Last but not least, consumer policy should pay more at-
and to consumers (see also the final recommendation tention to the new developments facilitating consumer
on expanding consumer research at the end of the fraud in the digital world.
summary).
The SVRV therefore makes the following recommenda-
tions with regard to the cross-cutting area of the digital
4.2 Digital world: Create digital world:
consumer skills and take
Recommendation 29: Take measures to close
account of the effectiveness of the existing gaps in digital consumer skills as
consumer information far as possible
The analysis of the situation of consumers in the digital Digital consumer skills are a prerequisite for consum-
world shows that there are gaps in digital consumer ers to be able to realise the potential benefits of digital
skills in Germany and that these skills are distribut- markets – better access to information, greater choice,
ed in a socially unequal manner. Differentiated policy potentially lower prices and more innovation in rela-
measures should therefore be swiftly taken to close ex- tion to products and services – and to gain sovereignty
isting skills gaps as far as possible, and the effective- in the digital world. The results of the empirical study
ness of such measures should be evaluated at regular carried out for this report lead us to the conclusion that
intervals. there are still large gaps in digital consumer skills in
Germany and that they are unequally distributed across
With regard to the information obligations on the pro- social strata. Consumer policy should therefore view
viders of digital services, a representative survey car- the results as an opportunity to take differentiated and
ried out for this report shows that only just over half prioritised measures to improve digital consumer skills
of current users of online comparison platforms have in Germany. This applies in particular to data protection
any interest in transparency information and that they skills, since the protection of personal data is currently
rarely use this information. Therefore, policy should of great concern to many people.
link the upcoming information obligations with a sys-
tematic supervision of digital service providers and the Recommendation 30: Accompany legal consumer
algorithms used. In this context, the Digital Services protection and consumer information measures
Act and Digital Markets Act proposed by the EU Com- (information obligations) with consumer education
mission in winter 2020/2021 and the rules on artificial measures
intelligence applications currently being drawn up are
central. From the point of view of the SVRV, such rules The results of the empirical study carried out for this
should be accompanied by consumer education meas- report suggest that, on average, only just over half of
ures, and, in addition, measures should be taken to re- current users of online comparison platforms have
duce the effort consumers perceive to be required to any interest at all in the possible problems connected
obtain information. with such platforms (amongst other things, rankings
and the associated algorithms and market coverage).
As regards the security of networked consumer devices Thus, consumers’ interest in transparency information
in the Internet of Things (IoT), consumer policy should appears to be low. The survey results show that a cen-
quickly drive forward the introduction of a practical IT tral reason for the lack of information-related activity
security label and continue and strengthen the promo- is probably disinterest. Information on the business
tion of targeted information and support. model, market coverage and the way user reviews are
generated appears to be irrelevant to the vast majority
of platform users.
