Shoptimised has joined other European Comparison Shopping Services in signing the CSS Group’s open letter to the European Commission regarding Digital Markets Act (DMA) enforcement in Google Search shopping features.
The letter is addressed to senior representatives of the European Commission and relates to the enforcement of Article 6(5) of the DMA, which is designed to prevent gatekeeper self-preferencing in digital markets.
For retailers, agencies and CSS providers, this matters because changes to how shopping results are displayed in search can have a direct impact on visibility, traffic, customer acquisition costs and consumer choice.
Search shopping features play an important role in how consumers discover products online.
For many retailers, these placements help products appear in front of shoppers at the point they are actively comparing options, prices and sellers. Any change to how those placements work can affect which retailers are seen, how traffic reaches merchant websites, and how efficiently businesses can acquire customers.
That is why the CSS Group is urging the Commission to make sure any remedy is tested against how the live eCommerce market actually works.
The group supports the Commission’s intervention to enforce the Digital Markets Act and prevent gatekeeper self-preferencing. The concern is that a badly designed remedy could create different problems for retailers, CSS providers and consumers.
In simple terms, the goal should be to improve competition without creating a new route to market that favours one dominant player, adds unnecessary friction, or makes it harder for merchants to reach customers.
Shoptimised supports the CSS Group’s view that DMA enforcement should be practical, evidence-led and commercially workable.
The open letter raises concerns around proposed search shopping layouts, including the risk of a closed or non-reciprocal shopping box model. The group warns that if Google operates a product search box, independent CSS platforms should be able to operate equivalent boxes on equal terms.
The concern is that a closed model could push retailers back towards Google’s own CSS as the default route to preserve visibility, rather than creating the fair and contestable market intended by the DMA.
The CSS Group is calling for remedies that:
These principles matter because the CSS market is not made up of one single model.
Some providers operate comparison websites. Others operate SaaS platforms or eCommerce marketing services. A practical remedy needs to reflect that variety, so competition is improved without creating new barriers for retailers, CSS providers or consumers.
One of the strongest points in the letter is the need for live market testing.
Search layouts affect visibility. Visibility affects traffic. Traffic affects acquisition costs, revenue and customer access.
If changes are made without testing their real-world impact, there is a risk that a remedy designed to improve competition could unintentionally damage the retailers and CSS businesses it is meant to protect.
The CSS Group is asking for real-world testing during any trial phases, including visibility trends, third-party CSS market share and merchant visibility. It also asks for testing data to be shared transparently with the affected industry so feedback can be taken into account.
The CSS Group represents a significant part of the European comparison shopping sector.
According to the open letter, the coalition includes businesses across price comparison websites, SaaS platforms and eCommerce marketing services.
Together, the group represents:
Shoptimised is one of the signatories to the open letter, alongside other comparison shopping services across Europe.
At Shoptimised, we work with retailers and agencies every day, so our concern is practical.
Retailers need a Shopping ecosystem that is competitive, transparent and commercially workable. CSS providers need fair access to visibility. Consumers need a shopping experience that remains useful, efficient and open to choice.
That is why Shoptimised is supporting the CSS Group’s open letter.
We support the aim of preventing self-preferencing, but we also believe any remedy needs to be tested carefully against real market outcomes.
The right outcome should protect competition, preserve retailer visibility and avoid creating unnecessary friction in the customer journey.
It should work in practice, not just in principle.
Read the CSS Group’s open letter to the European Commission here:
Read the official CSS Group press release here:
