EMA responds to Consultation on Scheme of a proposed Consumer Rights Bill:
The Irish government is proposing to update Ireland’s consumer rights law, by bringing existing law into line with the European Union (Consumer Information, Cancellation and Other Rights) Regulations 2013 as well as filling in gaps in consumer protection. They are suggesting in particular new requirements on gift cards and voucher products, including a ban on the use of expiry dates. The EMA’s response argues that:
- regulated e-money products, including gift cards and vouchers, should not come under the scope of the draft law, as there are already sufficient consumer protections in place under other legislation, such as the Payment Services Directive
- unregulated gift cards and vouchers should be permitted to continue to have expiry dates, for both commercial reasons and consumer preference. Without the use of expiry dates, many limited network gift card and voucher schemes would cease to operate, removing a valuable customer proposition from the Irish market.
The Department for Competition and Consumer Policy will consider the feedback they receive before announcing any next steps.