Overview

The Omnibus Directive (EU Directive 2019/2161), which came into force in January 2020, is intended to supplement and amend various directives in the area of consumer protection throughout the European Union (excluding the UK). The legislation intends to better protect consumers from false and misleading reviews in online commerce in the future by creating additional transparency obligations.

The Omnibus Directive will be implemented in Germany, among other things, with various amendments to the German Unfair Competition Act (UWG) on the 28th May 2022.

The new regulation stipulates the following to be adhered by all eCommerce businesses displaying Ratings & Reviews. You will also find appropriate guidance on how Bazaarvoice allows its customers to be compliant with it.

• It must be clear to consumers whether a review of a product originates from a user who has actually purchased/used the product.
• Companies that publish reviews must explain what verification mechanisms it has in place for this and must be transparent on whether reviews are checked to ensure that the review originates from a buyer/user of the reviewed product.
• If an authenticity check takes place, information must be provided on how it is checked.
• It must be transparently disclosed whether such reviews are incentivized, for example, whether the reviewer was paid for the review, whether a free product was made available, etc.

It must be clear to consumers whether a review of a product originates from a user who has actually purchased/used the product

Bazaarvoice offers its customers the capability to request reviews via Post Interaction Email (PIE), SMS or MMS, collectively termed as ‘Bazaarvoice Review Requests’. These mechanisms ensure the reviews are collected from earlier purchasers of the product. Read more about post-interaction Emails (PIE)

You can also use Data Injection and use UAS string to pass the Verified Purchaser information during review submission.

User Authentication String (UAS) is a series of key=value parameters used to communicate user ID and other user attributes to Bazaarvoice. Data Injection refers to the act of submitting data to Bazaarvoice in the user authentication string instead of using the standard submission form fields.

Once you collect the Verified purchaser information along with the reviews, you can make use of the Verified Purchaser badge to explicitly mention the review was provided by someone who has actually purchased the product. Click here to know more about how you can implement this.

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You must ensure that the Verified Purchaser Badge is turned on in the configuration.

Companies that publish reviews must explain what verification mechanisms it has in place for this and must be transparent on whether reviews are checked to ensure that the review originates from a buyer/user of the reviewed product

It is the responsibility of each Bazaarvoice customer to clearly explain to their consumers the meaning of review badges, purchase verification mechanisms, and authenticity checks.

You may use your policy page or create a container on the product page itself to educate consumers about this.

This can be accomplished by referring to the Authenticity Policy and this knowledge base article.

If an authenticity check takes place, information must be provided on how it is checked

If you use Bazaarvoice Review Requests such as Post Interaction Email (PIE), SMS or MMS to solicit reviews, then such reviews are marked as Verified Purchases. This is because these reviews are solicited from the messages that are only sent to the consumers who have bought the product earlier. Read more about post-interaction Emails (PIE).

Please clearly specify on your policy page if you are using other means to authenticate purchasers and classifying reviews as Verified.

It must be transparently disclosed whether such reviews are incentivized, for example, whether the reviewer was paid for the review, whether a free product was made available, etc.

Our clients can make use of Incentivized Reviews badge to appropriately tag qualified reviews to indicate the review is written by the person in exchange for an incentive such as entry into a sweepstake, product sampling or loyalty programs etc. Click here to know more about how you can implement this, and which reviews qualify for gaining Incentivized Reviews badge.

Organic Reviews

Organic Reviews are reviews collected on your website, app or similar platforms. If you collect organic reviews and wish to allow reviews only from purchasers of the product, then you may consider updating the Terms and Conditions to explicitly solicit this information from the consumers before they submit the reviews. Please note that the agreement text would be hosted on your site.

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Note that such reviews will not be badged for Verified Purchaser since no verification is done to confirm the authenticity of this information.

Click here to know more about submitting Terms and Conditions.