A COMPARATIVE ANALYSIS OF CONSUMER PROTECTION REGULATION IN THREE DEMOCRATIC COUNTRIES: AUSTRALIA, SWEDEN, AND THE UNITED STATES

Abstract

Consumer protection law is a broad body of law aimed at protecting consumers from the various harms that may be posed by certain business practices. When drafting and enforcing consumer protection law, states must balance the rights and interests not only of the consumer, but also of the business. Thus, how a country structures its consumer protection laws, policies and implementation can often reflect, in part, how a country has chosen to balance those interests. While several countries do not have any consumer protection measures or agencies in place, this paper takes particular interest in countries that do have substantive laws and institutions responsible for the protection of consumer rights. More specifically, this paper compares similarities and differences across four elements of different countries’ consumer protection law and regulation measures: enforcement/regulatory institutions; provision of educational resources to consumers; forum for consumer complaints and disputes; timely and speedy resolution for such disputes. As all of the countries being compared are member states of the UN, these broad but important elements of consumer protection standards provide a clear baseline for comparison. The intent of this paper is to identify and compare the consumer protection laws and policies within countries.