Education strategy for the consumer

One agrees with the very concept that regulators ought to come up with strategies to address specific issues. This is even commendable if stakeholders are involved. This process acquires greater legitimacy if it is conducted in a transparent manner. Such strategies should ideally form part of annual plans.

In his contribution of July 8, Francis E. Farrugia, chairman of the newly-formed Malta Competition and Consumer Affairs Authority, identifies as a primary target the drawing up of a national strategy for consumer education because this will be “the foundation of our activities”. For individuals unfamiliar with this territory this may sound great. But is it so?

Strategy is another word for “plan of action”. In this specific area, what are the targets? Before going down this road one needs to address other issues. What are the problems facing consumers? Do all markets function in such a way as to enable them to make confident choices? Are the difficulties faced by consumers in all markets similar or are they different?

In its exposé, the authority seems to have missed this step altogether!

Let us assume that a consumer education strategy should be a priority, dato ma non concesso, consequently, ideally consumers ought to be equipped to deal with different scenarios prevailing in the different markets.

Prior to proposing the drawing up of a national consumer education strategy one would have expected the authority to identify the markets it will address and, as a start, inform consumers. A consumer participating in the communications market may find specific market conditions different from those, say, in the energy, food or transport markets. Indeed, it is stated that it is “consumers who exercise free choice”. This is the point of it all. For example, in some markets consumers may be able to make a confident choice but are they able to do so in others? It is only upon identifying these circumstances that an apposite plan of action, a strategy, may be devised.

Unless it has not already done so, will the authority, as a start, identify these markets and communicate its findings to consumers?

In the absence of this first step, consumers still risk remaining uninformed, therefore, unaware and, consequently, vulnerable. This is worrying, particularly when the authority stated that it “is not going to wait for the national strategy exercise to be completed to start the educational programme”.

As an aside, one also asks what is the purpose of drawing up a strategy if the authority will still commence an educational programme?

A national strategy should address the participation of the Maltese consumer in the Maltese market with an eye that in some circumstances the Maltese consumer may well be participating in the globalised market.

Therefore, it is equally troublesome to note that some concepts, in what is presumed to be the launching of a process, seem to be ideas that have been drawn up by entities in other countries. One may naturally ask: Is there a need to reinvent the wheel? One may agree or disagree. Perhaps a reply is even immaterial here.

What matters most is that while there is no harm in referring to documents produced elsewhere one has to consider that these have been drawn up according to market circumstances that perhaps are different from those prevalent in Malta. Sometimes, these form part of a wider plan such as the one drawn up by the UK Office of Fair Trading.

It is not clear what bearing the following additional documents will have when the authority draws up a “national” strategy because it appears that, at this stage, they have been referred to: “assessment of the need for formal consumer education at secondary levels within a developing country: The case of Mauritius”; the notes of a seminar organised by the Department of Home Science, Ahemadabad, India on the “need of consumer education for today’s homemaker”, or “teaching consumer competences – a strategy for consumer education” drawn up by the Nordic consumer organisations and government agencies.

To conclude, a strategy is valid so long as it can achieve visible results. In the absence of this, such initiatives do nothing more except project a hallucination.

Dr Grima is legal counsel and council member of the Consumers’ Association.