LegalVideo Games Europe
Video Games Europe: Position on the Green Transition Consumer Directive
1 Jan 20236 pages~23 min full read
The European video games sector, representing a €23.3 billion industry with 90,000 employees and 250 million players, is actively lobbying to shape the EU's Green Transition Consumer Directive.
See it on page 6Video Games Europe supports the two-year commercial guarantee benchmark and the EU 2019/771 definition of 'durability,' which protects manufacturers from liability regarding piracy-related damage.
See it on page 2The industry opposes a blanket ban on software updates that reduce functionality, arguing that such restrictions could hinder legitimate service termination and inadvertently increase energy consumption.
See it on page 1The sector urges regulators to remove 'social impact' from the directive and rejects a mandatory Product Environmental Footprint (PEF) methodology in favor of flexible, science-based assessment tools.
See it on page 3Industry representatives argue that durability-guarantee information should be disclosed on product detail pages rather than immediately before checkout to prevent consumer distraction from other essential rights.
See it on page 2The 2023 position paper leverages data from 2020, noting a 22% growth rate for the sector and highlighting that 54% of the 250 million European players regularly use consoles.
See it on page 6The text articulates Video Games Europe’s response to the European Commission’s proposal for a Directive that would empower consumers in the green transition, emphasizing the sector’s commitment to sustainability while seeking regulatory clarity. It welcomes the incorporation of the EU 2019/771 definition of “durability,” noting that reference to “normal use” safeguards producers from liability for piracy‑related damage and that the two‑year commercial guarantee benchmark offers a balanced baseline for both consumers and manufacturers.
The commentary raises concerns about the proposal’s vague treatment of “environmental or social impact,” urging the removal of “social impact” and the adoption of flexible, science‑based assessment methods rather than mandating a single methodology such as the PEF. It supports mandatory consumer information on software updates that affect digital features but warns against blanket bans on updates that reduce functionality, arguing that such restrictions could impede legitimate service termination, increase energy consumption, and expose producers to disproportionate liability.
Regarding the Consumer Rights Directive, the text objects to the requirement that durability‑guarantee information be displayed “directly before the consumer places his order,” suggesting a pre‑contract disclosure on the product details page to avoid distracting consumers from other essential rights.
The sectoral scope covers the EU video‑games ecosystem, including consoles, PC, mobile and tablet platforms, and reflects data from 2020: €23.3 billion in revenue, a 22 % growth rate, 90 000 employees, and roughly 250 million players (51 % of the European population, with 54 % regularly using consoles). The position paper, dated January 2023, draws on the industry‑led Playing for the Planet Alliance (2019) and aims to shape forthcoming EU legislation.
