CAA Consumer Panel
Consumer Panel | Challenging, Influencing, Independent
Considering the consumer interest
The consumer principles
A straightforward way for regulators to think about the consumer interest in a structured
manner is to use the consumer principles. The principles were first set out by President
Kennedy in a speech to the US Congress in 1962 and later expanded on by the international
consumer movement. A similar list, expressed as rights rather than principles, form part of
the United Nations Guidelines for Consumer Protection.1 The principles are well-established
and are still commonly used by consumer organisations2 to work out how particular issues or
policies are likely to affect consumers. They can help to identify key subjects and questions
that need to be looked into further, and provide a consistent framework for approaching
issues.
The consumer principles are: access, choice, information, education, safety and quality,
protection of economic interests, fairness and equity, redress, sustainability, privacy and
representation.
Using the consumer principles in the context of aviation
One of the CAA’s purposes is to support consumers in relation to choice, value and fair
treatment. The consumer principles can help provide a framework to enable this.
Access
Consumers should be able to access services at a price and quality that suits their needs.
Barriers to access should be identified and addressed. Barriers could include price or
difficulty finding relevant information for example.
Choice
Where consumers have choice, they should be able to affect the way goods and services
are provided through the choices they make in the marketplace. In order to exercise choice
consumers, need to be able to find meaningful information, at the right time, and in a format
that makes it easy to compare. To be able to exercise choice confidently consumers also
need a strong regulatory framework to protect them if things go wrong.
Information
Consumers need clear, comparable, and timely information to be able to make decisions.
Conversely, having too much information, or information that is too complex or difficult to
compare, can impede decision making and lead to poor consumer choices. More information
1 https://unctad.org/system/files/official-document/ditccplpmisc2016d1_en.pdf. See also Consumers International,
the Consumer Principles: https://www.consumersinternational.org/media/2049/un-consumer-protection-
guidelines-english.pdf.
2 This paper is based on a paper published by the Legal Services Consumer Panel: Legal Services Consumer
Panel, The Consumer Interest, January 2014.
Consumer Panel | Challenging, Influencing, Independent
CAA Consumer Panel
Consumer Panel | Challenging, Influencing, Independent
is not always the best policy response, and regulators should test information remedies to
assess whether or not they work effectively in the consumer interest. Information in itself can
also be used by regulators and third parties to drive up standards.
Safety and quality
Consumers should have access to safe and high-quality services that meet acceptable
standards. Where a business is regulated it is important that consumers have confidence in
safety, that quality is effectively monitored and there are mechanisms in place to address
poor performance.
Protection of economic interests
Consumers should be able to access clear information when purchasing goods and services
so that they can be protected from risk and make effective decisions which enable them to
obtain value for money.
Fairness and Equity
Whilst the principle of access is covered above, there is a further expectation that
consumers will be treated fairly and equitably by providers. Many sector regulators have
explicit requirements (for example through licensing regimes) that consumers should be
treated fairly, and in most sectors alternative dispute resolution will also take into
consideration what is fair and reasonable in all the circumstances. With regard to equity,
regulators should ask themselves whether some, or all, consumers are unfairly discriminated
against.
Redress
Without redress consumers cannot enforce their rights and there is less incentive for
businesses to follow the rules. This can lead to undesirable outcomes including weakened
competition, unscrupulous businesses gaining an unfair advantage, and loss of consumer
trust in a market. To help overcome this it is important that consumers have access to a
simple, cheap, quick and fair system for dealing with complaints and disputes if things go
wrong.
Sustainability
The promotion of sustainable consumption patterns to protect the environment and meet
wider sustainable development goals. Consumers need to be provided with reliable and
trustworthy information and education about services to enable them to make effective
choices.
Privacy
The protection of consumer privacy should be considered when developing services.
Consumers need to be able to trust organisations to respect the privacy of data provided
when purchasing goods and services.
Consumer Panel | Challenging, Influencing, Independent
CAA Consumer Panel
Consumer Panel | Challenging, Influencing, Independent
Representation
The views, experiences and expectations of consumers should be taken into account in
service design and provision, and the process of decision-making should be transparent.
Businesses need to understand this to provide effective services, while regulators need to
understand it to design effective protections. Consumers are not one homogenous group
and work should be undertaken to segment consumer groups and reach a rounded
understanding of consumer needs and preferences. It is also important to consult specialist
representative bodies.
Education
Consumers today operate in increasingly complex markets, with ever greater amounts of
information and choice of products and services. Consumer education is critical in this
regard. It can be defined as a process of developing and enhancing skills and knowledge to
make informed and well-reasoned choices that take societal values and objectives into
account.3 It can also help build the confidence consumers need to operate in complex
markets.
3 See for example https://www.oecd.org/sti/consumer/44110333.pdf.
Consumer Panel | Challenging, Influencing, Independent
