Denmark’s response to the European Commission’s public consultation: Re-
view of the functioning of Regulation (EC) No 717/2007 (the "Roaming Reg-
ulation") and of its possible extension to SMS and data roaming services
Introduction
The Commission launched its public consultation
Review of the functioning of
Regulation (EC) No 717/2007 (the "Roaming Regulation") and of its possible ex-
tension to SMS and data roaming services
on 7
th
May 2008. It invited comments
on the functioning of the current Regulation on voice services, but also on the
possibility of including SMS and data roaming services within the scope of the
Regulation. Denmark (through the Ministry of Science, Technology and Innova-
tion) welcomes the opportunity to comment on the important matter of interna-
tional roaming.
2 July 2008
Voice roaming services
Generally, the Regulation on voice services has turned out to work as intended:
Prices have gone down and consumers benefit from improved transparency.
However, data from European Regulators Group (ERG) indicates that retail pric-
es remain clustered just below the price cap. This is a clear sign of lack of com-
petition which, in turn, leads Denmark to the conclusion that the current Regula-
tion on voice services needs to be extended beyond 2010.
Furthermore, the issue of billing units is an area of great concern. Judging from
the latest figures, Danish consumers pay at least 30 per cent more than the actual
call duration indicates. This is a result of the common European practice of per
minute billing. Denmark finds that this problem calls for urgent regulatory action
at EU level in order to secure that consumers do not pay for more than they use.
Finally, the mobile termination rates have dropped considerably more than antic-
ipated when the current Regulation was drafted. Therefore, from a Danish point
of view it is justified to adopt price caps that are lower than the existing ones in
order to reflect the reduced cost levels.
SMS and data roaming services
The National IT and Telecom Agency recently carried out a study of the prices
and costs for SMS and data roaming services with a view to assess whether regu-
latory intervention is needed. The study includes an analysis of cost estimates for
SMS, MMS and other data services. It is Denmark’s hope that the study will pro-
vide a valuable input to the Commission’s further review process. Therefore,
please find enclosed an English version of the study.
Generally, the study shows that the prices for sending an SMS, an MMS, or using
other data services when located in another EU country are very high, both in re-
lation to national prices and the real costs of providing the services. Both at the
wholesale level and the retail level, the prices charged by far exceed the costs.
In short, the study shows that retail prices for SMS roaming are 9 times higher
than the actual costs. Moreover, the roaming prices for MMS and other data ser-
vices are up to 6 times higher than the costs.
Ministry of Science
Technology and Innovation
Bredgade 43
DK-1260 Copenhagen
Phone
Fax
E-mail
Website
CVR-no.
+45 3392 9700
+45 3332 3501
www.vtu.dk
1680 5408
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