In a formal response issued today to the European Commission’s proposals, the GSMA points out that mobile operators offer roaming services as part of a package of interrelated services, which represents very good value for consumers. Across Europe, overall retail prices for mobile voice services (including both roaming and domestic services) have fallen at an average of 5% per annum over the past four years.

Data from a sample of key operators suggests that falls in retail roaming tariffs are accelerating, declining by an average of 8% across Europe last year. European operators are introducing innovative new packages that specifically give their customers better value on roaming services.

“Further roaming regulation is unnecessary and could have unforeseen consequences,” said Rob Conway, CEO and member of the board of the GSMA. “While we believe that competition is the best way to meet the needs of customers across the whole range of mobile services, the GSMA membership will continually explore ways in which further industry action might address particular concerns of customers and other stakeholders.”

More regulation would cut across the comprehensive telecoms regulatory framework that is already in place in the European Union, which enables national regulators to intervene if necessary. Overlapping regulation increases uncertainty and could put at risk further investment in networks and the development of new services, harming Europe’s broader competitiveness.

If the Commission continues to pursue the idea of legislation, it should first carry out a full impact assessment. This kind of analysis is a requirement of the Commission’s own internal process guidelines. The introduction of hastily constructed legislation could have unintended consequences, such as lower investment and less innovation, which would ultimately hinder the global competitiveness of European businesses.

“From the limited information publicly available, the European Commission’s proposals appear to be based on an outdated and incomplete view of the roaming market and the wider mobile industry,” added Mr. Conway. “Before taking the drastic step of bypassing the existing regulatory framework, the Commission needs to undertake a careful analysis of the fast-changing European mobile market and the potential impact of any further legislation.”

The European mobile industry, which reinvests a greater proportion of revenues than most other industries, has a strong track record of offering innovative new services and tariff packages to consumers. Operators are now investing in extending and upgrading third-generation mobile networks, allowing them to carry more traffic and rollout new services.

As a result, Europe’s telecommunications industry is offering consumers a wide and growing range of ways to communicate both at home and when they are travelling. New services, such as mobile email and instant messaging, and access technologies, such as WiFi, are further extending consumers’ communication options.