RD247 - ETNO Reflection Document with Comments on the Commission draft Recommendation on relevant product and service markets in the electronic communications sector
The proposed draft Recommendation is over-inclusive, i.e. subjects more markets to regulation than would be justified under the 3 criteria test set up by the Commission. As a result, many markets with a more advanced market development risk being subject to inappropriate regulation, impeding investment and stronger growth in Europe. To ensure harmonised principles across the EU and safeguard against inappropriate intervention at national level, the revised Recommendation should oblige NRAs to apply the 3 criteria test on each national market prior to regulatory intervention.
The proposed draft Recommendation is over-inclusive, i.e. subjects more markets to regulation than would be justified under the 3 criteria test set up by the Commission. As a result, many markets with a more advanced market development risk being subject to inappropriate regulation, impeding investment and stronger growth in Europe. To ensure harmonised principles across the EU and safeguard against inappropriate intervention at national level, the revised Recommendation should oblige NRAs to apply the 3 criteria test on each national market prior to regulatory intervention.
Please see the Reflection Document text for ETNO's detailed views on future inclusion in the Recommendation, or not, of retail calls markets, retail access markets, broadband markets, trunk and terminating segments of leased lines, transit services, mobile access and origination markets, broadcasting transmission markets, sms termination and whole-sale international roaming.
The proposed draft Recommendation is over-inclusive, i.e. subjects more markets to regulation than would be justified under the 3 criteria test set up by the Commission. As a result, many markets with a more advanced market development risk being subject to inappropriate regulation, impeding investment and stronger growth in Europe. To ensure harmonised principles across the EU and safeguard against inappropriate intervention at national level, the revised Recommendation should oblige NRAs to apply the 3 criteria test on each national market prior to regulatory intervention.
Please see the Reflection Document text for ETNO's detailed views on future inclusion in the Recommendation, or not, of retail calls markets, retail access markets, broadband markets, trunk and terminating segments of leased lines, transit services, mobile access and origination markets, broadcasting transmission markets, sms termination and whole-sale international roaming.