Consumer protection on large online platforms still insufficient

vzbv investigation highlights need to improve points of contact and transparency of recommender systems

  • The very large online platforms assessed do not always make it easy to contact them.
  • The very large online platforms and search engines assessed fail to make their recommender systems (sufficiently) transparent.
  • vzbv will consider legal action if platforms do not follow the rules.
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From targeted advertising and dangerous products to illegal content – to date, there has been insufficient monitoring of what happens on online platforms and search engines such as Google Search, Amazon, Zalando, and TikTok. The EU’s Digital Services Act (DSA) has introduced new due diligence obligations for platform operators. Very large platforms and search engines have been required to implement the first provisions since August 25. On the day the regulations entered into force the Federation of German Consumer Organisations (Verbraucherzentrale Bundesverband – vzbv) assessed selected service providers and identified insufficiencies regarding obligatory contact details and the transparency of recommender systems.

“Consumers need to know that they are protected against unfair practices on online platforms. The very large platforms have had enough time to implement the new EU regulations,” says Ramona Pop, Executive Director of vzbv. “vzbv has just carried out its first analysis, more will follow. We will take appropriate action against companies if they continue to fail to comply with the rules.”

Not always easy to contact the platforms in question

As of 25 August, very large online platforms are subject to various requirements, including providing an easily accessible single point of contact for users. vzbv examined Amazon, Apple App Store, Facebook, and TikTok, and found that while users can find a contact option, from vzbv’s point of view it is not always easily accessible. For example, contact details may be hard to find – in some cases up to five clicks are required before consumers can access the customer chat service or see an email address or phone number. Instead, self-help solutions are emphasised.

Ranking and recommender systems lack transparency

The service providers are also obliged to clearly state which criteria they use for recommendations and ranking. Consumers must be able to adjust these parameters.

vzbv’s analysis of Amazon,, Google Search, and Zalando shows that these platforms either did not implement these rules at all or did so insufficiently despite the fact that the implementation deadline had expired. Amazon, Google Search, and Zalando do not reveal the parameters of their recommender systems or how they can be adjusted in their General Terms and Conditions (GTCs). Only’s GTCs refer to a link with further information on how search results are ranked.

Users can adjust the order of products and services from Amazon,, and Zalando directly in the results list. However, only allows users to deactivate personal recommendations with a single click when using the platform. Zalando allows users to deactivate personalised content in the data settings. It is not clear whether this eliminates profiling, as foreseen by the DSA. Google Search requires at least three clicks to find information about the ranking of search results.

Making complaints via the consumer organisations

Consumers who encounter problems while using very large online platforms and search engines can inform the German consumer organisations of their experiences and complaints via the following link:

Background and methodology

vzbv analysed how very large online platforms and search engines are implementing the Digital Services Act (DSA). We focused on Article 12 (Points of contact) and Article 27 in connection with Article 38 (Recommender systems). We assessed Amazon, Apple App Store, Facebook, and TikTok with respect to Article 12, and Amazon,, Google Search and Zalando with respect to Article 27 in connection with Article 38.

The service providers in question belong to the group of “very large online platforms” (VLOP) and/or “very large online search engines” (VLOSE) that the European Commission identified as such on 25 April 2023. The new DSA rules apply to them as of 25 August 2023.

The evaluation took into account the available information on the companies’ websites or on the iOS apps. vzbv assessed the results using a system of categories based on the legal regulations. vzbv examined the companies in question on 25 August 2023.



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