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E-commerce: service providers have to offer more than just contact by e-mail

The questions before the European Court of Justice

This issue was referred to the ECJ by a German court, who had to decide whether an insurance company offering its services exclusively on the internet also has to mention its telephone number in addition to the postal and electronic mail already mentioned on the webpage. In this case, the telephone number was communicated only after the conclusion of a contract. However, interested persons were able to ask questions via an on-line enquiry template, the answers to which were sent by electronic mail.

The ECJ held that, before the conclusion of the contract, an e-commerce service provider is required to supply the recipients of the services, in addition to an e-mail address, with other information enabling the recipients to contact the service provider in a direct and effective manner. While this information does not necessarily have to be a telephone number, as an electronic template or other means may also suffice, there are situations where a telephone number cannot be dispensed with.

E-mail contact as sole means of communication with the service provider is not sufficient…

The ECJ argued that, despite encouraging the development of e-commerce, it does not follow from the E-commerce Directive that electronic commerce is considered isolated from the rest of the internal market. Accordingly, the mention of 'e-mail address' in the Directive does not mean that the Directive intended to dispense with other types of non-electronic communication which may be used in addition to it.

…also other means required to ensure communication in a direct and effective manner

Instead, the service provider is required under the E-commerce Directive to offer recipients of the service a rapid, direct and effective means of communication in addition to his electronic mail address. The question that arises then is whether information giving the recipients of the service access to another means of communication must necessarily include a telephone number.

No absolute requirement to offer contact via telephone

The ECJ rejected the argument that a service provider must indicate to the recipients of the service his telephone number, as only the telephone would be capable of satisfying the requirements of direct and effective communication. First, the ECJ noted that 'directly' does not necessarily require communication in the form of an exchange of words or an actual dialogue, but only the absence of an intermediary. Second, effective communication does not mean that the response given to a question posed must be instantaneous. On the contrary, a communication is to be regarded as effective if it permits adequate information to be obtained within a period compatible with the needs or legitimate expectations of the recipient.

Therefore the ECJ held that the service provider does not necessarily have to provide a telephone number, as there are other forms of communication that are able to satisfy the criteria of direct and effective communication, such as those established by personal contact at the premises of the service provider with a person in charge or by fax.

Electronic enquiry templates are sufficient, subject to one exception

The ECJ concluded by ruling that an electronic enquiry template (as used in the German case) may be regarded as offering a direct and effective means of communication, where the service provider answers questions sent by consumers within a period of 30 to 60 minutes.

This is, however, not the case in exceptional circumstances where a recipient of the service, after making contact by electronic means with the service provider, is, for various reasons, such as a journey, holiday or a business trip, deprived of access to the electronic network. In this case, the service provider has to offer, on request, access to another, non-electronic means of communication to ensure effective communication.

Conclusions

This ruling by the ECJ is important as it makes clear that, across all Member States of the EU, e-commerce businesses have to provide more than just an e-mail address as a means of contact prior to conclusion of the contract.

As a result of this ruling, e-businesses will have to offer an additional means of communication other than e-mail. This does, however, not mean that they have to introduce a general telephone number for all interested parties, as other (electronic and non-electronic) means of direct and effective communications are also sufficient. Only if recipients request a non-electronic means of communication due to lack of access to an electronic network, are service providers required to change their procedures by offering non-electronic means of communications (such as by telephone) to maintain effective communication.

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Christoph Jeloschek

Tel: +31 20 5506 846
E-mail: christoph.jeloschek@kvdl.nl

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