AIC Submits Comments on India’s Draft Model Framework for Guidelines on e-Commerce for Consumer Protection (Sept 2019)

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The Asia Internet Coalition (AIC) has submitted comments on the Draft Model Framework for Guidelines on e-Commerce for Consumer Protection to the Department of Consumer Affairs, Ministry of Consumer Affairs, Food and Public Distribution, Government of India. We commend the Department of Consumer Affairs on formulating the Guidelines for public consultation, with an objective to prevent fraud and unfair trade practices in the e-commerce sector and to protect the legitimate rights and interests of consumers.

We recognise the need to protect the interests of consumers and that e-commerce entity should have a responsibility to ensure a high quality of products and effective customer service.

Based on a detailed review of the Draft Guidelines, we make the following general observations:

  1. The Draft Guidelines does not fully consider the industry practices and business models of different types of e-commerce entities in India and abroad.
  2. The Draft Guidelines would impact the ability of Indian consumers to harness the full potential of the digital economy, the consequences of which could lead Indian users with limited access and choice in online services, thereby lagging behind their global contemporaries.
  3. The Draft Guidelines impose onerous and prescriptive obligations. Such compliance requirements will create market barriers, stifle business growth and competitiveness and could hurt ease of doing business, which may restrict the overall growth of India’s digital economy.