Morag Bond & Kate Reader Joint General Managers

Morag Bond & Kate Reader

Joint General Managers - ACCC Digital Platforms Branch

Level 27

135 King Street

Sydney NSW 2000

Via online portal

Dear Ms Bond and Ms Reader,

Re: Digital Platform Services Inquiry - March 2022 - Report on General Online Retail

Marketplaces

eBay Australia welcomes the opportunity to provide a submission to the Report on General

Online Retail Marketplaces. This submission builds on the initial discussions we have held with

the Digital Platforms branch in July 2021.

About eBay

For more than 25 years, eBay has enabled commerce and economic opportunity for individuals,

entrepreneurs, businesses and organisations of all sizes. Globally, there are more than

1.5-billion listings on eBay sites and 159-million active consumers in 190 markets.

Our role as a marketplace is to facilitate a safe and trusted way for businesses and consumers

to transact with confidence. While responsibility for listing on our platform remains with the

individual or business that originally listed the item, we support sellers and consumers with a

range of services, guarantees and feedback opportunities to ensure transactions can be

undertaken safely.

Our business model is illustrated in the diagram below.

In Australia, ebay.com.au has operated since 1999. 40,000 Australian businesses now sell via

our marketplace and nearly 12-million unique visitors come to eBay every month.

Over our 20 years of operation in Australia, eBay has positively supported and enabled

competition providing a platform for businesses of all sizes to compete and grow.

eBay has consistently evolved and innovated but remains a pure third-party online marketplace.

To be clear, eBay does not sell, ship or stock any items appearing on our marketplace.

Our support for competition and entrepreneurship is clearly highlighted in the role eBay has

played in the growth of new market entrants and e-commerce entrepreneurs. It should be

acknowledged that Australian marketplaces identified in this review (Catch and Kogan) were

created out of businesses originally developed on ebay.com.au. Similarly, the founders of

Afterpay built and leveraged their knowledge of e-commerce on eBay to drive new innovations

in payments while many pure play online retailers like The Nile have been able to grow from

small to larger businesses on eBay.

We are proud of our rich heritage and the positive contribution we have provided to enable

business and competition over our 20 years in Australia.

https://www.ebayinc.com/stories/press-room/au/top-ebay-sellers-expecting-biggest-christmas-sales-ever/

Our Unique Offering

eBay considers that the focus of this review on “general online retail marketplaces” limits

investigation into a significant and important part of the eBay marketplace and the competitive

environment within which we and our users operate.

Competition, in terms of the goods and services available through online retail marketplaces,

takes place not just between marketplace providers, but also with and between providers of

online retail sales and services, both from the demand and the supply sides. For example, eBay

has a vibrant community of consumer to consumer (C2C) sellers and for many this is an entry

point into e-commerce and business; a way to participate in recycle/re-use or to help generate

extra income when needed. Similarly, the competitive environment for marketplaces is

increasingly driven by niche verticals and specialist marketplaces.

Our responses to relevant questions posed in the issues paper are set out below.

1. Which platforms are the most significant general online retail marketplaces in

Australia?

As identified by the ACCC, eBay, Amazon, Kogan and Catch are significant general online retail

marketplaces in the Australian context, if significance is determined by reference to size,.

We emphasise however that there is a far more expansive range of online marketplaces which

are available to Australian consumers, each of which is significant in their own way. These are

both general marketplaces and niche verticals including Bunnings Marketplace, Myer

Marketplace, Qantas Marketplace, The Iconic, Temple & Webster, Everyday Market by

Woolworths, Wish, AliExpress, ASOS, GOAT, Grays, mydeal.com.au, Farfetch, Vestiaire

Collective, Ozsale, Depop, Poshmark, Etsy, HardToFind and StockX.

As noted above, as a marketplace which provides and facilitates both business to consumer

(B2C) and C2C transactions, eBay also competes with other consumer selling businesses such

as Facebook Marketplace and Gumtree.

2. What are the barriers to entry and expansion in Australia for the supply of general

online retail marketplaces? How have these changed over time?

The barriers to entry and expansion in Australia for the supply of general online retail

marketplaces are low, especially in terms of regulatory and financial barriers. This has not

changed over time.

We use the terms third party seller(s) / seller(s) interchangeably throughout this submission. As a pure third party online

marketplace, by definition all sellers on eBay are third party sellers (both B2C and C2C)

The relative lack of barriers to entry and expansion is evidenced by the fact that, since our

launch in Australia in 1999, eBay has witnessed the growth of the general online marketplaces

identified as part of this review as well as the expansive range of marketplaces and niche

verticals we have listed at question 1. We have set some of these out in a timeline below:

To start a general online marketplace in Australia you need:

● A digital platform – The emergence of new platform as a service (PaaS) offerings

such as Marketplacer and Mirakl have substantially reduced the technological

requirements for new marketplace entrants providing a platform to develop a

marketplace quickly and easily;

● An ability to facilitate payments - which can be done through agreement with a

payment service provider (who will then be responsible for the regulatory

requirements)

● To undertake marketing - to drive sellers and buyers to the marketplace

On that last point, the ability of a marketplace to expand is fundamentally driven by two factors;

its capacity to attract consumers; and its ability to retain sellers. This provides significant

opportunity for competition between marketplaces and the emergence of new marketplace

businesses into Australia reflects this fact. We outline this dynamic in the following diagram.

The ability to innovate is an important factor in the ability to expand as an online marketplace

provider. This can include:

● Developing and providing tools for sellers to assist them in promoting, selling and

receiving payment for their goods and services. This can be done “in house” by the

marketplace provider or through agreements with third-parties (such as research

companies and payment service providers);

● Developing and providing policies and programs to allow buyers to transact safely on the

marketplace. This can be as simple as putting in place systems to vet sellers to prevent

fraudulent transactions or to terminate rights to sell where there is failure to adhere to

policies designed to prevent abusive practices.

It should also be recognised that new software as a service (SaaS) offerings provided by

businesses including Shopify, Magento, Squarespace, Woocommerce and BigCommerce have

dramatically lowered the requirements for entry for new online retail offerings, significantly

expanding competition in general e-commerce since eBay’s launch in the Australian market.

3. To what extent do general online retail marketplaces compete with the third-party

sellers that are selling directly from their own online stores? To what extent do

they compete with physical stores?

As a pure third-party online marketplace, eBay partners with the 40,000 Australian sellers on

our marketplace but it does not compete with those sellers on the eBay platform. For

abundance of clarity, eBay does not sell, ship or stock any items appearing on our marketplace.

However, as a location from which sales and purchases of goods and services may occur, all

online retail marketplaces compete, indirectly with third-party online stores and physical stores,

as well as comparison sites like Little Birdie and search engines like Google Shopping.

From a demand side perspective consumers can, and do, search for goods and services online

through marketplaces and on third-party seller sites and at physical stores. From a supply side

perspective many third-party sellers advertise and sell products through online marketplaces,

their own online stores and at physical stores. Many well known bricks and mortar Australian

retailers (including The Good Guys, Chemist Warehouse, Big W, Bing Lee, Supercheap Auto

and Peters of Kensington) choose to leverage eBay as part of an omni-channel retail strategy.

As noted in the issues paper, despite the tailwinds of COVID, online retail spend in Australia is

only 16% of total retail spend . This is far lower than more developed e-commerce markets such

as the UK (26%) and Korea (45%) . The vast majority of Australian retail trade (both food and

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non-food) still occurs in bricks and mortar stores.

4. To what extent do third-party sellers make their goods available across multiple

marketplaces? Are there reasons for picking one marketplace and not the other?

To what extent can sellers bypass the marketplaces to reach consumers?

As online marketplaces have continued to enter the Australian market, an increasing number of

retail businesses are looking to sell on multiple marketplaces.

eBay facilitates multi-channel selling through a range of integrations with website services such

as Shopify, BigCommerce and Wix. eBay can be easily added for businesses selling on multiple

marketplaces or via their own website. We also work collaboratively with a range of

multi-channel integration partners such as Maropost Commerce (formerly Neto), City Beach

Software (Omnivore), Channel Advisor, Intelligent Reach, Merchant Spring, Codisto, M2EPRO

CrescoData, Comestri, Feedonomics, Fooition and Zellis as they look to support businesses

selling across multiple marketplaces.

As noted in our response to question 2 above, the general attraction of any marketplace for a

seller is its audience size and level of engagement with consumers.

However, recent research undertaken by Newgate Research for eBay indicates that beyond

audience size, there are other benefits of online marketplaces that sellers rate as very important

and would drive decision making on which marketplace to sell.

Findings taken from Online Marketplaces Research (Third Party Seller Community) an online community forum of 52 Australian

third party online sellers conducted by Newgate Research for eBay Australia July 2021

https://kosis.kr/eng/

https://www.ons.gov.uk/businessindustryandtrade/retailindustry/timeseries/j4mc/drsi

https://www.abs.gov.au/articles/online-sales-june-2021-supplementary-covid-19-analysis

The safety and security of payments and increasing the likelihood of products appearing in web

searches were emphasised as very important benefits for both low volume sellers (<$50K p.a.)

and high volume sellers (>$50K p.a.).

eBay does not place restrictions on sellers also utilising their own websites or other

marketplaces to sell their goods. Our member to member contact policy makes it clear however

that while open communication between sellers and consumers is encouraged, it is a breach of

the eBay User Agreement to make offers to buy and sell outside of eBay. For instance, buyers

and sellers can’t engage in any action with a user on the site designed to complete or facilitate a

transaction outside of eBay or use contact information obtained through an eBay transaction to

offer to buy or sell an item outside of eBay. Doing so is a breach of policy and eBay’s User

Agreement.

Attempts to bypass eBay and transact off platform exposes consumers to potential scam

behaviour and means protections offered (such as the eBay Money Back Guarantee) are not

available. It is also a poor experience for consumers to be directed to other sites to complete

their purchase when they think they are transacting through eBay. eBay also does not allow

sellers to use the contact details of buyers that we provide to them for the purposes of delivery

to then send unsolicited marketing to buyers - doing so is a breach of eBay’s User Agreement,

User Privacy Notice (section 20) and SPAM Policy. Our links policy also makes it clear that

listings cannot include links to direct consumers to sites other than eBay.

While attempts by sellers to push transactions off our marketplace are not allowed, we enable

sellers to build their brand and market to our 12-million unique monthly visitors in other ways.

For example, eBay has recently launched a new coded coupon offering which allows sellers to

directly offer consumers discounts on the seller’s eBay listings . A seller can make the coded

https://sellercentre.ebay.com.au/coded-coupons

https://www.ebay.com/help/policies/listing-policies/links-policy?id=4248

https://www.ebay.com.au/help/policies/payment-policies/offers-buy-sell-outside-ebay-policy?id=4272

https://www.ebay.com.au/help/policies/member-behaviour-policies/membertomember-contact-policy?id=4262

coupon publicly visible (on ebay.com.au) on their listings or share it privately through their own

marketing channels.

Another example is a digital “eBay Store” where a seller can list all their inventory for sale on

eBay under their own logo and branding. Many sellers utilise an eBay store to grow their overall

business which in turn allows them to drive traffic to their own website or even their own

physical store via click and collect. An example is set out below:

5. Are any general online retail marketplaces considered a ‘must have’ for Australian

third-party sellers or for sellers of a particular category of goods?

As noted in our response to question 1 above, there are a growing number of both general

online retail marketplaces and niche vertical marketplaces in Australia. The increased

prevalence of multi and omni channel selling suggests sellers are using a mix of marketplaces,

webstore and in-store strategies to engage with customers, with no one marketplace being a

“must have”.

6. To what extent do consumers use more than one marketplace? What role do

subscription/loyalty schemes have in consumer choice of marketplace? What role

do non-price factors, such as the level of customer service or ease of access to

refunds have in consumer choice of marketplaces?

As noted earlier, over recent years there has been significant growth in the number of general

online marketplaces and direct online retail offerings in Australia. In an increasingly competitive

retail environment, consumers have more choice than ever before. Consumers are leveraging

this expansion in choice to utilise multiple marketplaces (both general and niche) when making

purchasing decisions.

Reflecting this expansion in choice, preliminary (beta) data developed by Similarweb shows that

over the past 12 months 79.6% of visitors to Australia’s top 100 e-commerce sites, visited 6 or

more other e-commerce sites .

Beyond price factors, e-commerce consumers are generally driven by convenience with fast

and free delivery of goods, exclusive offers and free returns being key considerations in addition

to fundamental trust and safety considerations.

Recent consumer research undertaken by Newgate Research for eBay Australia indicated that

when considering to purchase via an online marketplace, consumers rated as very or quite

important considerations:

· Safe and secure payment system (95%)

· Knowing personal data is secure and won’t be misused (93%)

· The platform is fair in resolving disputes between buyers and sellers (90%)

· Has a large range of items to choose from (87%)

· Offers free or cheap delivery options (87%)

As some non-price factors may present a “premium service”, subscription programs are utilised

to meet consumer demands and to drive brand loyalty. eBay Australia’s subscription program,

Findings taken from Online Marketplaces Research (Consumer Survey) a nationwide survey of 1,200 Australian consumers

conducted by Newgate Research for eBay Australia August 2021

Source: Similarweb (Beta data) Timeline: Past 12 months (Aug ‘20-July ‘21) Data: Estimated % of the audience of top

e-commerce and shopping sites (as defined by Similarweb based on estimated desktop traffic volume) that visits each site

exclusively vs. multiple sites

eBay Plus, offers members exclusive deals, fast and free express delivery upgrades on millions

of Plus items, free returns and partner offers such as discounted movie tickets .

The eBay Plus badge indicates that a listing is covered within the program. This is beneficial not

just to consumers but to eBay sellers as well. Benefits for sellers include:

- Accessing more engaged consumers

- Access to exclusive eBay onsite promotions

- Increased visibility in eBay search

- Subsidised postage

For a seller listing to qualify for eBay Plus they are required to meet a range of criteria

including:

- Maintain a Top Rated or Above Standard rating

- Ensure all listings are located within Australia

- 0-1 day handling (time between transaction and the seller handing off to a shipping

carrier)

- Accept 30 day returns for change of mind

Non-price factors do have a role in consumer choice. As a general observation, the extent to

which these factors will drive decision making will often be dependent on the category a

consumer may be looking to purchase in (for example a free return may be more important for a

consumer buying clothing than it would be if the same customer was looking to purchase a

book).

7. To what extent can consumers bypass marketplaces to buy directly from sellers?

Consumers always have the choice as to where, and from whom, they acquire goods and

services. As noted in our response to question 4 above, while eBay monitors attempts by both

consumers and sellers to transact off platform where the contact has been made on the eBay

platform, there are no barriers to a consumer buying goods directly from a seller. Indeed, unlike

other marketplaces, eBay enables sellers to use and promote their own brand on eBay.

Anecdotally, many sellers use eBay to build their brand. The growth of eBay businesses such as

Catch and Kogan into marketplaces in their own right is evidence of this.

Many sellers will utilise marketplaces as an additional sales channel to their existing online

offering. As a recent example, during Victoria’s extended COVID lockdown in 2020, Yellow Earth

Co., a manufacturer and retailer of sheepskin clothing, footwear and accessories, needed to

move quickly as their physical retail stores were forced to close their doors. Sales from Yellow

A full list of seller criteria can be found here:

https://www.ebay.com.au/help/selling/listings/creating-managing-listings/selling-ebay-plus?id=4756

https://www.ebay.com.au/ebayplus/home

Earth Co.’s own e-commerce platform and a new store on eBay allowed the company to keep

its six full-time staff and casual retail employees in work. As Director of Yellow Earth Co.

Matthew Liu stated:

“That income stream (physical retail) pretty much became zero but the online side allowed us to

continue generating income into the business and help pay wages and keep some of the jobs

running as well.

“Just a few weeks ago before lockdown began, online accounted for just 5 per cent of our

overall sales, whereas it’s now around 60 per cent. eBay is already responsible for half of these

sales which is more than we could have ever expected in such a short time”

8. What services do marketplaces provide to assist or enable sellers to sell their

goods? How have these changed over time?

As noted above, seller engagement is critical to the health of a marketplace. eBay provides a

range of services to assist sellers build and grow their business online. eBay undertakes

marketing; provides data insights and tools; runs promotions via our home page and through

emails and other owned channels; provides account management support; selling and listing

integrations; negotiates competitive postal rates; establishes competitive third-party

warehousing options; provides various seller protections; as well as enabling new payment

options.

We outline some of the additional services offered by eBay below:

Terapeak Product Research

Terapeak uses recent eBay supply, demand, and pricing data to help sellers determine what to

sell, when to sell it, and at what price. It offers recent marketplace price trends and real-world

sales data for millions of items to optimise listings and improve sales. Terapeak allows sellers to

grow inventory on eBay by identifying key trends and opportunities. In 2017, eBay acquired

Terapeak to support sellers in running their business .

In April 2021, Terapeak Product Research (which provides insights on listings, how returns and

shipping options drive performance and trends in prices, sales and product availability) was

made free to all eBay sellers. Terapeak Sourcing Insights, which provides deeper and more

current data on demand and supply trends, is free to access for all levels of eBay store

subscriptions.

https://www.ebayinc.com/stories/news/ebay-signs-agreement-to-acquire-terapeak/

https://www.ebay.com/help/selling/selling-tools/terapeak-research?id=4853

https://www.news.com.au/lifestyle/fashion/fashion-trends/sales-of-sheepskin-moccasins-and-boots-boom-during-lockdown/news-stor

y/6a0581bacca95ed6aee399485a11f947

Postage Labels

With eBay Postage Labels, eBay sellers can pay for their postage and print their Australia Post

and Sendle postage labels, all on eBay. Postage is offered at a discounted rate.

Afterpay on eBay

In 2020, we introduced Afterpay on eBay. This change offered consumers a new way to pay for

items on eBay but also provided this payment option to eBay sellers free of charge (eBay pays

the merchant fee for these transactions). The introduction of this new payment option was a

strong driver for sales growth for businesses across eBay . It was also made available free of

charge to C2C sellers on pre-owned items, a global first for this premium payment method.

Seller Growth Support

Through our partnership referral program eBay provides certain referred new business sellers

seller growth support to help them hit key milestones in their online selling experience. The

program helps sellers overcome initial barriers to listing inventory, managing their first sales and

ensuring they have their postal policies set up correctly.

Advertising and Marketing Services

eBay provides new and established sellers with a variety of marketing and advertising services,

primarily designed to either grow broad awareness of a product, seller or brand, drive lead

generation, or promote and launch products across our marketplace. These services typically

use our unique view of consumers to holistically tailor campaigns for seller success.

Promoted listings are offered to help sellers boost the visibility of their eBay listings and reach

new consumers.

9. Are there any trends in consumer behaviour or preferences, such as increased

online purchasing that have or will affect general online retail marketplaces? If so,

describe what they are

The COVID-19 pandemic brought a number of significant changes in consumer behaviour.

As our Lockdown: One Year On report identified, COVID-19 saw a generational shift in how

Australians shop online.

During lockdown periods Generation Z (18-24 years old) did more than half of their shopping

online (57 per cent), while Baby Boomers (60+ years old) posted the biggest increase on their

pre-pandemic online shopping figures (69 per cent).

https://static.ebayinc.com/static/assets/Uploads/PressRoom/Local/eBay-Lockdown-Report.pdf?utm source=301Redirect&utm medi

um=301Redirect&utm_campaign=301Redirect

eBay’s partnership referral program is building a range of new partnerships with business services and industry associations that

support small to medium businesses

https://www.afr.com/companies/financial-services/afterpay-deal-has-helped-lift-sales-ebay-says-20201209-p56m14

While improved mobility has generally seen moderation in online shopping levels, on a

pre-pandemic basis, more Australians than ever before are looking to buy online. In recognition

that older and potentially less digitally literate Australians are shopping online, eBay has

supported the efforts of the e-Safety Commissioner’s Be Connected program. Be Connected is

aimed at increasing the confidence, skills and online safety of older Australians when they use

the internet.

As part of Be Connected, in 2020 eBay assisted in the development of a free module to take

older and novice users through the basics of setting up an eBay account, making a purchase as

well as how to list an item for sale . Building digital literacy and confidence is one of the best

ways to keep individuals safe when trading online and to also engage our community during

times of isolation.

One of the positive changes we’ve also seen through the COVID-19 period has been increasing

consumer preferences towards Australian Made goods. Searches for ‘Australian Made’ items on

eBay were up significantly throughout 2020, rising by more than 430 per cent in July.

To make it as easy as possible to buy local on our platform, as part of Australian Made’s

first-ever partnership with an online marketplace, we created Australian Made on eBay a one

stop shop for Australian Made across categories including fashion, health, beauty, automotive,

and home and garden.

Streaming video and movie services are also driving consumer purchasing habits on online

marketplaces. As an example, the 2020 Netflix series The Last Dance (focussing on the

Chicago Bulls final championship run) saw a rapid increase in searches for basketball

memorabilia and merchandise on eBay (up 283%). Similarly, the period drama series Bridgerton

saw a 357% increase in searches for regency fashion (tiaras and shawls) on eBay following its

launch in Australia.

10. Has competition, or potential competition, in the supply of general online retail

marketplaces services been affected by:

a) acquisitions of start-up companies

b) entry into the market by international businesses

c) the acquisition or development of new technology

d) acquisitions of companies operating in related sectors within the mobile

and / or desktop device ecosystem?

e) the current COVID-19 pandemic and the increase in online purchasing by

Consumers

If so, please describe how.

https://www.ebay.com.au/e/special-event/australian-made

https://beconnected.esafety.gov.au/topic-library/introduction-to-buying-and-selling-online

eBay launched in Australia over 20 years ago. Our business has continued to evolve and adapt

with changes in consumer demand, seller behaviours and competition from both domestic and

international competitors.

eBay is a business that was founded on an ethos of providing a marketplace where all sellers

could compete regardless of size. We have welcomed the entry of new competitor marketplaces

as good for the market and reflective of the maturing of online retail in Australia. New entrants

drive healthy competition for both marketplace consumers and sellers.

While we do not suggest that any of the factors above have negatively impacted competition,

we do hold concerns that the current application of the Goods and Services Tax (GST) on low

value goods may be having distortionary effects on competition between Australian online

marketplaces and other international e-commerce platforms.

As you may be aware, the Australian Treasury Laws Amendment (GST Low Value Goods) Act

2017 (the Act):

● Made foreign vendors, as well as re-deliverers and ‘electronic distribution platforms’

(EDPs), such as eBay, liable for GST on low value imported goods sold to an Australian

consumer

● Required foreign suppliers that make sales of more than $75,000 to consumers in

Australia each year to register for and collect GST.

eBay Australia has worked hard to update our systems, communicate to our sellers and engage

with the ATO to ensure we remain compliant with these requirements.

Under this model, without any direct action by them, a foreign supplier selling via a marketplace

like eBay to consumers in Australia has GST automatically applied (eBay collects and remits).

On the other hand, a foreign supplier who sells direct to Australian consumers doesn’t have to

charge GST until they exceed $75,000 in sales.

While eBay believes there may be more efficient models of collection, we hold concerns that

there are business platforms that may not have been contemplated at the time of this legislation,

or through its implementation and operation by the ATO, that should also be liable for collection

of low value GST.

Businesses that provide e-commerce platform support for online stores and payment platforms

are good examples. As these businesses charge transaction and payment fees on sales from

those that utilise their platform, they would have the capability to assess GST taxable supplies,

collect and then remit GST.

As it stands, a foreign business that chooses to sell into Australia via an EDP has GST applied

from their first sale. Allowing foreign businesses that sell low value goods into Australia via other

platforms without having GST applied is unfair. It creates distortions in the market, by enabling

businesses who sell to Australia via an online store to charge 10% less than their eBay store or

other domestic competitors.

This encourages consumers to shop on less trusted websites which do not provide guarantees

on purchases, reduces government tax revenue and most importantly reduces the

competitiveness of Australian retail.

We note the Board of Taxation is currently reviewing the Act , but would welcome consideration

of these issues by the ACCC from a competition perspective.

11. What is the process for getting a product listed on a general online retail

marketplace? What is the process for removing a product from the marketplace?

Has this process changed over time?

The process for listing an item is set out on eBay’s help page .

Sellers can utilise eBay’s quick listing tool which provides the core features they need to start

selling or alternatively, sellers that sell frequently and in bulk may use the business tool to list.

Sellers can also utilise third party integrators to list such as Maropost Commerce Cloud

(formerly NETO), Shopify, or otherwise list items directly through API integrations.

When listing an item, sellers can provide photos, brand, item description, item condition (e.g.

used, new, certified refurbished etc.), physical details about the item (“item specifics”), pricing

format (i.e. auction or fixed price) and service options (i.e. handling time, shipping options,

returns).

Sellers listing via one of eBay’s listing tools can choose to use eBay’s product catalogue, which

is an online library of details and images for products across a wide range of categories. The

product catalogue pre-fills product information like brand, model number, dimensions, colour,

capacity, compatibilities and also provides professional photos. Importantly, we do not insist on

product-catalogue matching in order to sell on eBay.

Rules for listing on eBay are set out in our listing and selling policies . eBay also has rules

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around prohibited and restricted items and policies to monitor and mitigate risk and fraud . All

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eBay’s risk and fraud policies aren’t publicly disclosed to mitigate users attempting to circumvent them.

https://www.ebay.com.au/help/policies/prohibited-restricted-items/prohibited-restricted-items?id=4207

https://www.ebay.com.au/help/policies/selling-policies/selling-policies?id=4214

https://www.ebay.com.au/help/policies/listing-policies/listing-policies?id=4213

https://www.ebay.com.au/help/listings/creating-managing-listings/creating-listing?id=4105

https://taxboard.gov.au/review/low-value-imported-goods-review

of these policies ensure that eBay keeps its community of users safe and that local legal

requirements are met.

As set out in the eBay User Agreement, eBay may take action if listings or sellers do not comply

with eBay’s policies, including by delaying the listing of an item, deleting the listing, or by

restricting a users’ activities on the site

eBay has automated models which may prevent an item from being listed on eBay. These

models look to detect whether a potential listing is in breach of certain policies (for example, the

prohibited and restricted items or counterfeits items policies) or represents a potential risk (such

as fraud). These models monitor at both an item and account level.

While some listings will be automatically blocked by these models, others will be referred for

internal review by our teams. These reviews assess whether a seller or the specific listing is in

breach of policy.

Even where a listing has been initially allowed, eBay continues to monitor the marketplace and

will take action on listings and sellers that are subsequently identified as breaching policy.

Where a listing has been removed, the seller is advised of the removal via the eBay message

centre (and their registered email) and the reasons for the removal (the policy which the listing

was in breach).

Seller account restrictions are advised via the same channels. As these restrictions may relate

to potential fraud, specific reasons for the restriction are not generally disclosed. In most cases,

eBay grants the restricted seller opportunities to provide further information to assist in

reviewing the restriction.

While eBay makes significant investments in technology to stop items listing on our marketplace

that should not be listed, we also encourage our community of users to report problems,

offensive content, and policy violations. In particular, eBay's Verified Rights Owner (VeRO)

Program works to ensure that listed items do not infringe upon the copyright, trademark or

other intellectual property rights of third parties. eBay’s dedicated VeRO team investigates

reported violations of third parties’ intellectual property rights, and where appropriate, it may

take action and remove listings.

In addition, eBay’s Regulatory Portal launched in Australia in 2021 is a first for an online

marketplace. The Portal empowers trusted authorities from around the globe, including the

ACCC and the Therapeutic Goods Authority, to efficiently report and remove listings for illegal or

unsafe items. It allows a regulator to remove listings from the eBay marketplace without

additional approval from eBay itself.

https://www.ebayinc.com/stories/press-room/au/ebay-launches-new-regulatory-portal-to-further-protect-consumers/

https://www.ebay.com.au/help/policies/listing-policies/selling-policies/intellectual-property-vero-program?id=4349

eBay continuously reviews and adapts its policies and processes to improve the detection of

breaches of policy and risk. While specific policies do not change frequently, internal triggers

and models are updated on an ongoing basis to mitigate risk and adapt to the changing

behaviour of fraudulent sellers.

12. How effective are the key marketplaces’ current processes for reviewing and

approving products? Do these processes operate to ensure low quality and

products which may cause consumer harm are excluded?

eBay does not have a process for specifically reviewing products, nor does it “approve”

products. However, listings and sellers are expected to comply with eBay’s policies (as noted

above).

Our global efforts to both reactively and proactively address issues relating to prohibited and

restricted items, listing and intellectual property violations are illustrated below:

Case Study - COVID 19

While eBay has effective processes in place, we also look to evolve and adapt to emerging

challenges. Our willingness to adapt to keep our community safe was demonstrated in 2020 as

we responded to COVID 19.

eBay has a policy of not allowing sellers to list items that attempt to capitalise on disaster or

tragedy . eBay has also implemented an explicit price gouging policy to make it easier for our

31 32

users to report non-compliant listings.

https://www.ebay.com/help/policies/prohibited-restricted-items/price-gouging-policy?id=5106

https://www.ebay.com/help/policies/prohibited-restricted-items/disaster-tragedy-policy?id=5051

As we’ve noted above, ordinarily, as our community identifies instances of items in breach of our

policies (or as our team undertakes sweeps of the platform), we remove those listings and when

necessary block the associated user's account.

Due to the unprecedented nature of COVID 19 and the associated panic buying it inspired, the

sheer volume of sellers that were looking to list items at excessive prices both in Australia and

globally put our systems under immense strain. In large part, these sellers were private

individuals trying to resell products they had bought from a retailer.

To stop this practice, eBay globally took proactive steps and restricted the listing of key items

including face masks and hand sanitiser to only a handful of sellers.

In addition to masks and sanitizers, eBay Australia also restricted toilet paper to approved

sellers. Restrictions were also applied to other products subject to panic buying (for example

baby formula or nappies) to business sellers.

Our approach to restrict the listing of these items to certain sellers was taken as it was not

technically feasible to implement a large-scale enforcement of the numerous products in these

categories based on automated price assessments.

This practical action worked to ensure that those trying to take unfair advantage of the situation

were stopped but also and importantly that consumers could still access these goods from

legitimate sellers at a time of elevated demand. We welcomed acknowledgement of these

efforts by the ACCC .

13. What processes are in place (if any) for taking action in response to consumer

reviews? Are products ever removed in response to poor consumer reviews?

eBay has processes in place for consumers to provide product reviews. In addition, to help

encourage positive behaviours on eBay, we provide the ability for both seller and consumer

feedback.

Product reviews are an important tool to help consumers complete their entire shopping journey

from research through to purchase. Based on information a seller provides in relation to their

listing on eBay, relevant reviews will be matched for that item. While eBay does moderate

reviews (as described below) it does not take action in response to product reviews.

eBay provides 2 types of product reviews:

○ Verified Reviews: Left by consumers we know have purchased the item on eBay

○ Unverified Reviews : Left by customers who have purchased the item elsewhere

https://www.accc.gov.au/speech/managing-the-impacts-of-covid-19-disruption-on-consumers-and-business

When searching for an item a star rating at the top of each listing is matched to a product

review. The star rating is an average of all scores submitted for both types of reviews.

To help address the potential risk of manipulation by sellers, our reviews policy makes it clear

that listings for the following types of items are not allowed:

● Social media likes, followers, shares, or any type of social media engagement

● Services to leave, manipulate or improve reviews about products or companies

The policy means that an individual cannot make a listing offering social media likes, shares, or

other social media engagement on eBay sites. Services to leave or manipulate reviews about

products or companies also cannot be offered.

Like any breach of eBay policy, reporting channels are available for our community of users if

they identify this behaviour and, where relevant, regulatory authorities can report on these

matters as well. Appropriate action such as administratively ending or cancelling listings, hiding

or demoting all listings from search results, lowering seller rating, buying or selling restrictions,

and account suspension may be applied against a seller who breaches this policy.

As noted above, as an open marketplace, poor consumer reviews in and of themselves are not

a basis for the removal of a listing on eBay. Where there is a breach of policy relating to a listing

being unsafe or prohibited, action is taken quickly to remove the item.

eBay also provides an opportunity for consumers to feedback on their transaction experience

with a seller which we explain in detail in our response to question 29 below.

14. To what extent do the marketplaces’ terms and conditions affect the pricing of

goods by sellers?

The price at which goods are listed on eBay is the decision of the seller.

From time to time, eBay offers promotions on its platform that may be fully or partially funded by

the participating sellers. In its funding agreements with those sellers, eBay requires them to

(among other things):

● agree not to increase the listing price of any included items prior to the start of the

promotion so as to make the offer appear more attractive;

● act in good faith at all times in connection with the promotion;

● maintain price parity during the promotion between the items listed on their own

website/s and any of their items listed on www.ebay.com.au which are included in the

https://www.ebay.com.au/help/policies/listing-policies/social-media-reviews-manipulation-policy?id=5031

promotion so as to ensure that the discount offered to buyers in the promotion is not

rendered false or misleading.

● ensure that the discount represents a true and accurate percentage discount on the

price at which such items are sold for the duration of the promotion; and

● comply with all applicable laws and in particular the Australian Consumer Law.

While pricing decisions are solely the decision of sellers, eBay encourages sellers to offer free

postage for items they list. It's been consistently shown , when buying online Australian

consumers expect and search for free postage. We communicate to all sellers that offering free

postage can make a big difference to their sales. If offering free postage isn’t an option for a

seller we suggest that they set postage discounts when consumers reach a minimum spend.

To be eligible to participate in the eBay Plus program, eBay sellers must offer free express

shipping on eligible items. eBay contributes up to $4 for express shipping of these items.

Where free postage is offered, a seller will need to factor this into the final sale price of an item.

As noted in our response to Question 17 below, while free delivery is not preferenced in our

search algorithm, sellers can expect that as items with free delivery convert better (as

consumers regularly look for items with free delivery) they may see organic improvement in their

search results on eBay.

15. What fees and charges do marketplaces charge to third-party sellers? How have

these changed over time and how do these affect sellers?

There are a number of fees charged for selling on eBay. For some fees, the amount charged will

vary based on the category the seller is listing in and the store package that a seller has

subscribed to.

It should be noted that as eBay is currently transitioning away from PayPal for payments

processing, sellers on eBay are experiencing changes to their fees . Sellers will be charged

fees inclusive of payments processing. Previously sellers were charged this separately by

PayPal when selling on eBay.

While sellers will see higher fees from eBay (as we now manage the payment process), most

can expect to see overall savings as they transition onto the new payment system as well as

other benefits including expanded payment options, consolidated reporting and improved

integrations.

As all sellers will be onboarded to this new system, we have only outlined fees under our new

managed payments structure.

https://sellercentre.ebay.com.au/managed-payments

https://www.retailbiz.com.au/online-retailing/aussie-consumers-expect-free-delivery-and-returns-as-standard/

The main fees charged to sellers are as follows

Final Value Fees

Once an item sells, a seller is charged a percentage of an item’s total sale price. For most

categories, the Final Value Fee for selling without a store subscription is 13.4% (GST incl.) or

lower plus a $0.30 transaction fee. For eBay store subscribers, Final Value Fees range from

5.5% - 13.1%(GST incl.) depending on store tier and the category in which an item is sold, plus

a $0.30 transaction fee.

Store Subscription Fees

eBay offers a range of store subscriptions for higher volume and business sellers. With an eBay

Store, sellers can display their listings in a single, branded location and also benefit from

inclusive listings, discounted fees and additional tools to manage their business.

All eBay Store subscription packages offer lower Final Value Fees and benefits (as compared

to selling without an eBay Store). In addition store subscribers have access to additional tools to

manage and promote their business, although some of these may incur additional fees. Sellers

can choose between a Basic, Featured or Anchor store package with a scaling set of fee

discounts and benefits.

Other Fees

Some fees affect a smaller number of sellers and may apply in certain instances such as listing

in Classified Ad format, listing in the Motors or services categories, upgrading or scheduling a

listing, or for listings associated with international selling.

Over the last 12 months, eBay has removed fees to list an item. A fee is still however charged

for excessive listing (applied when a seller exceeds 250,000 listings per month). This is to cover

additional costs associated with the management of such a large volume of listings such as

hosting, storage and computer infrastructure to serve fast search results.

Further detail on seller fees are available directly from the help pages on ebay.com.au .

16. What are the benefits of the additional services provided by marketplaces to

third-party sellers (for example: warehousing, distribution)? To what extent are

sellers able to use services other than those offered by the online retail

marketplaces?

https://www.ebay.com.au/help/selling/fees-credits-invoices/ebay-stores-selling-fees?id=4809

https://sellercentre.ebay.com.au/ebay-stores

Although eBay does not directly provide warehousing or distribution services, we partner with

third-party service providers to offer such support to sellers on our marketplace.

Key benefits to sellers of utilising these services include reduced rates, simplified integration

processes, faster delivery times and professional inventory management.

Generally eBay allows third-party fulfilment, including drop shipping. However, we don't allow

third-party fulfilment if it could be confusing or misleading for the consumer (for example,

because the packaging used makes it appear that their item was purchased from another

retailer or marketplace instead of on eBay), or if the consumer's personal data is not sufficiently

protected.

Our policy also makes it clear that a seller listing an item on eBay and then purchasing the

item from another retailer or marketplace that sends it directly to a customer is not allowed.

17. How important is it for a product to be displayed prominently on a marketplace for

the success of the product? How important is the product category or categories

that a product is assigned to?

When consumers search on eBay, the default order of results is generally called Best Match .

This ranking (ordering) is designed to show the most relevant listings, taking into account the

criteria users find most important when they're deciding what to buy.

Final search ranking considers a number of different factors. These include:

● How closely the listing matches the consumer's search terms

● How popular the item is

● The price of the item

● How complete the listing is (Does it have photos? Does it have an item description?)

● The listing terms of service, such as a seller’s return policy and handling time

● A seller’s track record when selling on eBay

● Whether a listing is being promoted or not, with these listings clearly marked as

sponsored

● The overall diversity of the results set (e.g. considering if varied item conditions are

shown or not based on the query)

Sellers who follow best listing and selling best practices will maximize the chance to see their

items appear higher in search results. Competitive pricing, reasonable postage, and outstanding

customer service are a great starting point for sellers. To help to appear higher in search results

we also recommend sellers take the following actions:

https://www.ebay.com.au/help/selling/listings/listing-tips/optimising-listings-best-match?id=4166

https://www.ebay.com.au/help/policies/selling-policies/selling-practices-policy/thirdparty-fulfilment-policy?id=4718

https://sellercentre.ebay.com.au/ebay-fulfilment-partner-program

● Create complete and accurate listings (this helps eBay match more precisely to

consumer searches)

● List in the most accurate category (a seller can also choose to list items in a secondary

category)

● Use high quality photos

● Provide all selling terms (such as postage and handling costs and any international limits

on listings)

● Maintain a positive sales history

● Handle customer complaints in a timely and professional manner

● Use a reliable, tracked delivery service such as Australia Post or Sendle.

In general, our approach to search results allows for any seller to be able to succeed in securing

sales. Intermingled in the same results can be large brick and mortar retailers, online pure play

distributors, small businesses and consumer sellers often selling a used version of the item.

Ultimately, our search ranking is optimised towards answering a consumer’s query most

accurately, and therefore securing a sale for the seller that best meets that query. All the above

factors are balanced in a multi-stage machine learned model to meet that outcome with no

ability to manually and arbitrarily weight different factors independent of these stated goals.

A typical eBay search result is set out below:

Our search manipulation policy makes it clear however that sellers attempting to manipulate

eBay's search and browse experience by adding popular keywords in listings that don’t have

any relation to the seller’s items, or using other tactics that could mislead consumers, is not

allowed. Consumers are encouraged to report listings that they feel are breaching these rules.

18. How do marketplaces determine how, and in which order, products are displayed?

Which products (if any) benefit most from this? How has this changed over time?

Please see our response to 17 above.

19. Are third-party sellers informed of changes made by marketplaces as to how

goods are displayed? If so, are sellers provided reasonable information on the

changes?

From time to time, eBay provides updates on changes across our marketplace. Updates relating

to the functionality of eBay are generally provided through our regular Seller Updates issued

two or three times a year. Seller Updates provide details on key changes and how sellers can

prepare for them.

While we don’t provide sellers with detailed technical information on how the Best Match

algorithm mathematically computes internal functional values as we believe this exacerbates

risks of gaming, we do provide relevant detail on changes to factors that feed into Best Match

results and thus provide information on how relative ordering of results are optimized. As an

example, our Autumn 2021 Seller Update provided details on new Item Specifics for certain

categories for goods . Item Specifics are the details relating to a listing and are a factor that will

assist a seller’s items appearing in search.

20. How has the methodology that marketplaces use to determine which goods to

display prominently affected how sellers market their goods?

Best Match encourages sellers to focus on sound business practices and deliver great value

and service to consumers.

The methodology and factors that feed into Best Match help to drive better marketing

approaches by sellers by favouring listings that include relevant details, have clear and clean

photos and list in the right category. It bears repeating that eBay’s search ranking works to

optimise consumers' searches by matching them with items that they are looking to buy. Items

that are well priced, from a known manufacturer, with a free delivery option and from a seller

that does not have a track record of poor customer service will perform well with best match and

https://sellercentre.ebay.com.au/2021-autumn-seller-update/listing-optimisation

https://sellercentre.ebay.com.au/2021-autumn-seller-update/home

https://www.ebay.com.au/help/policies/listing-policies/search-manipulation-policy?id=4243

lead to conversion. Meeting these requirements help sellers of all sizes to compete effectively

on eBay.

21. What range of consumer data can be collected from the use of marketplace?

Section 4 of eBay’s User Privacy Notice (“UPN”) sets out the range of consumer data collected

by eBay about its users. That data includes:

● data provided by the user when using the service or creating an account (section 4.1);

● data that is automatically collected from the user when using the service or creating an

account (section 4.2);

● data collected in connection with cookies and other similar technologies (section 4.3);

● data collected from other sources (to the extent legally permissible); and

● social network data shared by a user with eBay.

The data includes name, address, phone number, email address, transaction related data such

as bids, purchases and sales, delivery address, billing details, financial information data and

content shared with other users. It also includes data generated through user actions on the site

such as saving sellers, user’s searches, advertising preferences, computer and connection

information including IP address and accessed pages, frequency and duration of visits,

interactions with eBay’s advertising partners and the segment into which the user falls (eg,

male, 20-49 yrs old, interested in sneakers). eBay also collects consumer data from other

sources where permitted such as public sources (eg for demographic data) and credit agencies.

a) To what extent is this data accessible to the seller, and for how long?

Sellers get access to all data that is generally available to other users of the eBay site (for

example, User IDs and feedback data relating to other users).

Data that is accessible to sellers over and above the data that is generally available to users on

eBay, comes in two forms.

First, data that is shared with the seller after a transaction has occurred includes buyer name,

buyer phone number, ship to name, ship to address, and ship to phone number. This data is

available for viewing by sellers for up to 90 days from the transaction date . Sellers can also

download their own selling history through downloadable reports on eBay’s Seller Hub for up to

2 years..

Secondly, and as noted in our response to question 8 above, data is made available to sellers

through Terapeak, which is an analytics tool eBay makes available to assist sellers with their

selling journey. eBay provides all sellers with free access to Terapeak Research which provides

sellers with insights from analyses of millions of listings across eBay’s global platform including

sales data, listing formats, average sales prices, shipping costs and buyer search terms. Sellers

with a store subscription are provided access to Terapeak Sourcing Insights which also provides

https://www.ebay.com.au/help/policies/member-behaviour-policies/user-privacy-notice-privacy-policy?id=4260

sellers with data for items that are in or out of stock and category research on high demand low

inventory items on eBay.

b) To what extent is this data accessible to the marketplace or other third-party?

Please see our response to question 21 in respect of the data collected and therefore

accessible by eBay.

The circumstances in which eBay makes data available to third parties are set out in section 5

of eBay’s UPN (Purposes and legal basis for data processing and categories of

recipients):

● to fulfil eBay’s contract with its users and to provide eBay’s services (section 5.1);

● to comply with eBay’s legal obligations (section 5.2);

● to protect the vital interests of users (section 5.3);

● for legitimate interests of eBay or third parties except where overridden by the user’s

interests, fundamental rights or freedoms (section 5.4);

● with the user’s consent (section 5.5);

● sharing with other eBay group companies (section 5.6); and

● in the case of provision of payment services where such information is required to be

shared (section 5.7).

The categories of third party recipients to whom consumer data is accessible are set out at the

end of each subsection of section 5 in eBay’s UPN.

For third party vendors with whom eBay shares personal data eBay has a robust Vendor

Management Compliance program including Vendor Security Assessments run by its

Information Security (Infosec) and Privacy teams who clear the third party prior to the sharing of

any data. This ensures that eBay has the proper due diligence and governance in place for

existing and new vendors. Any agreement with a third party of this nature will include specific

data protection clauses that apply a GDPR standard with which the third party is required to

comply.

● eBay has also set up a Data Council, made up of senior members from the legal,

compliance, privacy, and product departments.

● Before certain data is shared with third parties it has to be approved by the Data Council

a part of whose role is to conduct a review to make sure that our privacy statements and

agreements are upheld, adequate contractual protections are in place and to maintain

customer trust in eBay.

eBay stores personal data in accordance with applicable data protection laws to the extent

necessary for the processing purposes set out in eBay’s UPN (described below). When a user’s

data is no longer needed for the purposes for which it was collected, eBay will delete that data

in accordance with its data retention and deletion policies unless we are legally obliged to keep

a user’s personal data for longer (e.g. for tax, accounting or auditing purposes). The retention

periods depend on the type of data and the purpose for which the data is retained. More detail

on storage, duration and erasure of personal data is set out in section 7 of eBay’s UPN.

22. For what purposes is this data collected? To what extent does analysis of this

data affect future browsing and purchasing by consumers?

Purposes of data collection

The purposes for which eBay collects consumer data are listed in detail in section 5 of the UPN

and are summarised in our response to question 21. Such purposes include: providing the

services to eBay users and enabling the performance of transactions, enabling delivery of

purchased items, provision of eBay’s payment services, prevention, detection and mitigation of

illegal activities (eg fraud, money laundering and terrorist financing), complying with legal

obligations to which eBay is subject, analysing and improving the Services (by reviewing site

usage data to improve the user experience, customising page content and for product

development) and personalisation, measurement and improvement of our and third party

advertisements.

Analysis of data which affects future browsing and purchasing

Analysis of the data allows eBay to enhance the customer experience in many different ways,

particularly on the eBay home page, within the search experience and in the View Item

experience each of which may affect users’ browsing and purchasing.

What is displayed to the user when they browse the site may depend on whether eBay can

recognise the user (e.g. if they are signed into their account). For example, the home page for a

user signed into their account may be populated with modules that show recently viewed items,

watched items, items which are frequently searched for and items recommended for them,

based on their past browsing and/or purchasing history.

As noted in our response to question 17 above, when a buyer searches for a specific item on

the eBay site, eBay’s Best Match algorithm determines the order of the results that is displayed

to them. There are a number of factors considered by the algorithm to sort listings, based on

data that eBay collects. Notwithstanding the operation of the Best Match algorithm, users can

change the order in which items appear or exclude items from their search by adjusting the

search filters available to them (eg, moving from Best Match to Lowest Price).

As discussed further in response to question 36, eBay uses consumer data to determine

marketing segments that will receive specific marketing offers. In addition, analysis of consumer

data is used to surface third party advertisements on its site. These experiences, in turn, may

affect users’ browsing and purchasing experience.

23. What terms and conditions are in place between marketplaces and third-party

sellers for the access of data by the marketplaces? What data are sellers required

to provide marketplaces access to?

Sellers on the eBay site agree to eBay’s User Agreement , UPN and, for managed payments

sellers (described below), eBay’s Payments Terms of Use .

User Agreement

By accepting the User Agreement:

a. users agree that the User Agreement, and the UPN apply when using the eBay

Services;

b. Sellers using eBay’s managed payments service agree to a number of things including

to provide the payments entity with information about the seller or their business required

for eBay to meet its ID verification, AML and CTF legal obligations and provide bank

account information; and

c. users (including sellers) agree that when they upload content onto the eBay site, they

grant eBay a licence to use the content (s.6 Content).

UPN

eBay’s UPN (also discussed throughout these responses) sets out what personal data is

collected by eBay and how a user’s personal data is processed (see UPN sections 4, 5 and 6

and our responses to questions 21 and 22). It also includes notice of the fact that eBay and

selected third parties may use cookies and similar technologies to provide the user with an

enhanced user experience or to show the user personalised advertising (section 9, which also

includes a link to eBay’s Cookie Notice.)

Payments Terms of Use

eBay is now managing payments for sellers on the ebay.com.au site. Sellers whose payments

are managed by eBay agree to the Payments Terms of Use under which they agree to provide

eBay with:

- information required to establish their use of the service including information for

verification purposes and AML/CTF compliance. Such information includes identity

verification through the provision of name, address, phone number, date of birth,

taxpayer ID number, bank account information, government issued identification as well

as required business details including beneficial owners, directors, officers and contact

information.

24. To what extent do marketplaces have processes in place to resolve third-party

sellers’ complaints? How effective are these processes?

As a third-party online marketplace, eBay seller complaints commonly relate to disputes with

consumers and breaches of listing rules.

eBay provides a range of self-help and reporting tools to assist in the management of

complaints as well as active monitoring of the marketplace through both advanced technology

https://pages.ebay.com.au/payment/2.0/terms.html

https://www.ebay.com.au/help/policies/member-behaviour-policies/user-agreement?id=4259

and human review. eBay’s focus is on tools for quick and smooth consumer to seller resolution,

process transparency and the surfacing and removal of banned items and bad actors.

In the first instance, we encourage sellers to utilise the information set out under our Seller Help

pages . When logged into eBay, this page will indicate any issues with a seller's account such

as listing or policy violations, issues with their returns or payments. The page also sets out how

these items can be resolved, as well as provides options to request assistance or status

updates on prior requests.

As noted elsewhere in this submission, when on eBay, all users (sellers and consumers) need

to follow our rules and policies . These rules set out our expectations of member activity on the

site, the actions we’ll take to keep sellers and consumers safe when transacting and how we'll

protect them if something goes wrong.

Our Seller Help pages also provide sellers with the ability to report consumers who they identify

as not following the rules .

Where we need to step in and assist, eBay customer service support teams are available:

- Mon-Fri 8am-8pm

- Sat- Sun 9am-7pm

Customer support can be reached during these times via eBay Customer Service .

To contact customer support, sellers can either choose a topic or click on the “contact us” icon

at the bottom of the page. Sellers don’t have to be signed into their account to contact customer

support.

For most help topics, all sellers can access both chat and voice support. In addition, we have a

dedicated phone number and email address for sellers who are part of eBay’s account

management program.

Beyond our mechanisms for self and direct resolution of seller complaints, eBay works

constructively with Australian regulators and ombudsmen / commissioner services to maintain a

safe and fair marketplace.

eBay has recently developed a seller support playbook for the Australian Small Business and

Family Enterprise Ombudsman. The Playbook details the key self service and supported

reporting pathways for sellers as well as escalation opportunities for the Ombudsman to utilise.

http://www.ebay.com.au/help

https://www.ebay.com.au/help/selling/resolving-consumer-issues/reporting-issue-consumer?id=4084

https://www.ebay.com.au/help/policies/default/ebays-rules-policies?id=4205

https://www.ebay.com.au/sellerhelp

In addition, to gain direct insight into issues impacting on sellers and emerging trends, eBay

convenes a weekly eBay Seller Panel between senior eBay managers and 10-12 eBay sellers.

Sellers are drawn from a range of retail categories and business types (bricks and mortar,

multi-channel and online pure play). Meeting agendas provide sellers with the opportunity to

provide feedback on potential changes, suggest improvements as well as provide feedback and

escalate issues that they are hearing from the wider seller community.

25) Do third-party sellers have any concerns about their relationships with the relevant

online marketplaces?

eBay has assumed that this question is directed at third party sellers and accordingly, does not

respond.

26. To what extent are marketplaces’ relationships with third-party sellers affected by the

marketplace acting as a seller in the same product category?

While eBay is a pure third-party online marketplace and cannot comment directly on these

relationships, we are aware of seller concerns relating to competitor marketplaces which also

act as a seller in the same marketplace. These concerns relate to the potential competitive

disadvantage and conflicts of interest emerging. A recent LinkedIn post by a well known

Australian multichannel retail advisor reflects these concerns:

https://www.linkedin.com/posts/timdavieszellis_amazons-figures-arent-a-concern-unless-activity-6828513203874471936-Y4Lv

Recent research conducted by Newgate for eBay Australia in relation to online marketplaces,

asked participants (Australian third-party online sellers) for their views around global proposals

to restrict third-party online marketplaces from selling their own branded products.

Feedback indicated that while third-party sellers were generally comfortable with the concept of

online marketplaces selling their own branded products, when acting as a retailer in their own

marketplace, the customer data and analytics online marketplaces hold, gives these businesses

a clear and unfair advantage. As one seller noted it was a:

“Major conflict of interest and not in the spirit of good business”

eBay sellers engaged in the research were most concerned about the capacity of large online

marketplaces being able to source from their suppliers at a lower price. This may be a driver in

their decision making to sell on a pure third-party online marketplace.

Seller sentiment on this issue was also impacted by a number of other considerations:

● If marketplaces prioritised their own products over others

● The type of product the seller stocked (niche, handmade versus everyday items)

● Concern that platforms might drop small sellers so they can sell own products

● Cutting into the profits of marketplaces might diminish their marketing budget (impacting

the marketplaces wider performance)

A recently launched Australian online marketplace MedCart explained its decision on not

competing with sellers on its marketplace:

https://www.medcart.com.au/

Findings taken from Online Marketplaces Research (Third Party Seller Community) an online community forum of 52 Australian

third party online sellers July 2021

“Our job is to get them (third-party sellers) sales,and provide a seamless customer experience

for our customers, but we’ll never enter into that arena of competing. It’s very tempting

sometimes to do that, but we’ve started off with that as our vision and we will be keeping that

into the future”

As the marketplace model continues to evolve in Australia, new entrants will need to balance

their desire to build their own product lines, against third-party sellers preferences to be able to

compete fairly on a platform.

27. What information are third-party sellers required to provide to customers

about the product for sale, including in relation to quality or price?

eBay requires that all sellers on its platform provide the following information to consumers in

their listings: title, category, condition, photo, certain required item specifics , item description,

selling format (auction style or fixed price), price (for auction style listings a ‘starting price’, and

for fixed price formats a ‘buy it now’ price), quantity, payment options, postage options, and the

item location. The information that sellers are required to provide is set out as part of the listing

creation process. Listings that do not contain all of the required information cannot be uploaded.

There are also some policies which require sellers to include certain information in their item

description. For example, eBay’s Alcohol policy requires sellers to display their license number

and a disclosure pertaining to the age and location of the consumer, in their listing.

As the eBay marketplace is based on listings and not on products, it is not technically feasible

for our systems to provide price assessments without determining exactly what item a given

listing was offering, its quality and the quantity being offered.

We have noted above the steps eBay took during the COVID-19 period in 2020 to address

potential consumer harm arising from price gouging of essential items. We have also taken

steps to address the resale of event tickets at inflated prices through the onboarding of

regulatory authorities onto the eBay Regulatory Portal to accelerate removal of listings that are

in breach of our policies.

28. What information do app marketplaces provide customers about the product

or sale, including in relation to quality or price?

The Victorian Department of Jobs Precincts and Regions (responsible for the Major Events Act 2009) has been onboarded as a

reporting entity to eBay Regulatory Portal.

https://www.ebay.com.au/help/policies/prohibited-restricted-items/alcohol-policy?id=4274&st=3&pos=1&query=Alcohol%20policy&i

ntent=alcohol%20policy&lucenceai=lucenceai&docId=HELP1178

Item specifics are attributes, such as brand, make, model, size, colour and style, that sellers can add to their listings. Item

specifics match with the filters that consumers use on the eBay website and it allows sellers’ inventory to be more easily found. eBay

mandates some item specifics (“Required Item Specifics”) and these vary depending on the category the item is being listed in. For

example, the Required Item Specifics for an item listed in the Patio & Garden Tables category would be “Item Width” and “Item

Height”.

https://insideretail.com.au/e-commerce/5-e-commerce-experts-weigh-in-on-the-acccs-marketplace-inquiry-202108

We assume for the purposes of our response, the ACCC is referring to online marketplaces and

not app marketplaces.

As mentioned above, eBay is not the party that lists items for sale on its marketplace. Third

party sellers provide information to eBay about an item they wish to sell when they create an

item listing, and eBay displays that information to potential consumers via a “View item” page.

The view item page of an item for sale includes all information about an item provided by a third

party seller, and (where available) also displays product reviews and a seller’s positive feedback

rating.

In relation to price, eBay provides a “great price” signal in search. This signal appears on the

most competitively priced items from an aggregated list of item listings from trusted sellers who

are selling the same item in the same condition.

29. What processes are in place for consumers to rate and review products? To

what extent do reviews and ratings affect consumer choice of a product?

Consumers on eBay are able to leave reviews on products (“Product Reviews”) and/or leave

feedback on a seller following a transaction (“Seller Feedback”). Product Reviews and Seller

Feedback assist consumers in making informed decisions about not just what they are buying

but who they are buying from.

Our response to question 13 above provides the process by which consumers can rate and

review products.

Seller Feedback is not a review of the product, but rather, allows consumers to provide reviews

about a specific seller’s performance (including their communication, postage time and item

description).

Seller Feedback can be left by consumers after every purchase . After completing a purchase

with a seller, a consumer is able to provide Seller Feedback on the specific seller. Consumers

can:

https://www.ebay.com.au/help/buying/leaving-feedback-sellers/leaving-feedback-sellers?id=4007

● Select an overall Feedback rating – positive, neutral, or negative

● Rate aspects of the transaction – including whether the item arrived on time, the

accuracy of the item description, shipping costs, and the seller's communication

● Write a comment about their experience

Users also receive a feedback score based on the feedback that has been left for them.

Consumers can view a Seller Feedback score on the right panel of the “View Item” page. As

explained on eBay’s Help Page , a seller's feedback score is displayed as a percentage

beneath their username on their listings. This is based on other users’ experiences with them as

both a consumer and a seller on eBay. For example, if a seller has a score of 99.5% Positive

Feedback, it means that 99.5% of their consumers left positive feedback about their experience

with that seller. Below is an example of how a seller’s feedback score is displayed on an item

listing.

In addition, consumers can also view a seller’s entire feedback profile (by clicking on the

numbers next to a seller’s username on their listing). The feedback profile contains their

feedback ratings, detailed seller ratings (i.e. ratings on item description, postage and

communication), as well as details of all feedback received and left for others. Below is an

example of a seller’s feedback profile.

The positive Feedback percentage is calculated based on the total number of positive and negative Feedback ratings for

transactions that ended in the last 12 months, excluding repeat Feedback from the same member for purchases made within the

same calendar week (eBay time). Note: This could mean that the number of ratings used for this calculation is different from the

same number shown in the recent ratings table on the left.

https://www.ebay.com.au/help/buying/resolving-issues-sellers/seller-ratings?id=4023

Seller Feedback and Product Reviews are run through filters that check for things like profanity,

personal information (email, phone) and external hyperlinks prior to the review and feedback

being published on the site.

For Product Reviews and Seller Feedback not caught by eBay’s filters, there are reporting

functionalities for users to report policy violations. In the case of Product Reviews, this allows

users to report reviews that violate eBay policies (such as eBay’s policy on profanity). Below is a

screenshot of the choices users are given when using this functionality to report a Product

Review. In the case of Seller Feedback, sellers can report when they are unhappy with

feedback left by a consumer. eBay removes such feedback where it breaches its policy.

All eBay users can refer to Product Reviews (if applicable), and Seller Feedback prior to making

a purchase. All of this information helps consumers be more informed about their purchase,

based on the opinions and experience of other users.

30. What is the process for consumers to return products and/or report low quality

or harmful products, and what role do marketplaces play in these processes? How

effective are these processes for consumers?

It is important to remember that transactions occurring on the eBay platform take place between

the seller and the buyer and that eBay does not have visibility to the actual products supplied in

any transaction. However, when listing an item on eBay, sellers are required to include

information on whether or not they accept returns due to a change of mind of the buyer. If a

seller does accept returns for this reason, they must confirm how long a consumer has to return

it after the sale, and who pays for return postage . A seller’s acceptance of returns for a change

https://www.ebay.com.au/help/selling/managing-returns-refunds/handling-return-requests/setting-return-policy?id=4368&st=12&pos=

1&query=Setting%20up%20your%20returns%20policy&intent=return%20policy&docId=HELP1307

of mind means a consumer can return an item for any reason, including because they changed

their mind or chose the wrong item.

If a seller chooses to not offer returns due to a change of mind of the buyer, the consumer can

still return an item if the reason they are returning it falls within the scope of eBay’s Money Back

Guarantee program (described below), or if they otherwise have rights in accordance with the

statutory guarantees under the Australian Consumer Law. Our policies make clear that outside

of any returns arrangements stated by sellers, consumers are not precluded from exercising

their consumer law rights against a seller.

The eBay Money Back Guarantee (“eMBG”) covers most transactions on eBay and means

consumers can get their money back if an item does not arrive, is faulty or damaged, or doesn't

match the listing. The eMBG is not a product warranty, and does not replace consumer’s rights

under the Australian Consumer Law.

As set out in clause 10 of the User Agreement and the eMBG policy, all users agree to comply

with the eBay Money Back Guarantee policy. Users also acknowledge and agree that eBay may

exercise our reasonable discretion to make a final decision on any case – including an item

returned for remorse reasons – where a consumer and seller cannot come to agreement.

How a return is managed depends on the return reason provided by the consumer. If a

consumer returns an item because they changed their mind, management of the return will be

governed by the seller’s return policy. If the consumer is returning the item because it didn’t

match the seller’s item description, this would be managed in accordance with the eMBG (or

directly between seller and buyer under the consumer guarantee provisions of the Australian

Consumer Law, if the buyer chooses to do so).

eBay offers a returns platform to manage communication between consumers and sellers in

respect of returns. When a consumer opens a return, the seller is notified and is given 3

business days to resolve the consumer’s issue.

○ If the consumer and seller are able to come to an agreement, the case can be

closed by the consumer or it will close automatically after 30 days from the date

of the transaction.

○ If the consumer and seller are unable to come to an agreement, either party can

escalate the case to eBay. If eBay decides in favour of the consumer, the seller is

required to issue a full refund to the consumer. In some circumstances, eBay

may also step in and make a decision on a case after 3 business days without

requiring the consumer to escalate.

https://www.ebay.com.au/help/policies/ebay-money-back-guarantee-policy/ebay-money-back-guarantee-policy?id=4210&st=12&pos

=1&query=eBay%20Money%20Back%20Guarantee%20policy&intent=ebay%20money%20back%20gu&docId=HELP1238

http://pages.ebay.com.au/returns/

31. How easy is it for consumers to seek (and receive) a repair, replacement or

refund for a harmful, faulty or not-fit-for-purpose product?

Consumers’ rights to seek repair, replacement or refund in respect of a product are a matter

between the consumer and the seller and are, where appropriate, governed by the rights and

obligations set out in the consumer guarantees in the Australian Consumer Law. While eBay is

neither supplier nor manufacturer of any products sold through transactions on its platform,

eBay does offer consumers the ability to quickly and easily open a return on eBay when they

follow the steps detailed on our customer service pages within the relevant return timeframe .

Items which are faulty or not-fit-for-purpose are also generally covered by the eMBG.

Where a consumer needs additional assistance with a return, they can contact customer service

for support . eBay customer service will provide assistance when the contact falls within the

Seller’s return policy or within the eMBG timeframe.

After the period stipulated in the seller’s return policy and eMBG timeframe lapses, consumers

are directed to contact the seller directly regarding any issues they may have with their item(s).

As set out above, the eMBG is not a product warranty, and does not replace consumer’s rights

under the Australian Consumer Law rights. Consumers are always free to separately pursue

their consumer law rights against a seller and this is made clear in the “Return Policy” section of

each item listing.

32. What risks are there to consumers when making purchases on a general

online retail marketplace? What measures are in place to protect consumers from

the risks of scams, or harmful products, on marketplaces? What processes are in

place to deter sellers from offering harmful products?

As noted elsewhere in this submission, trust and safety are critical elements of any marketplace.

eBay works to ensure that our marketplace is always a place where consumers can buy with

confidence.

On-platform transactions are generally protected by the eBay Money Back Guarantee (eMBG) –

ensuring consumers can get their money back if an item didn't arrive, is faulty, damaged, or

doesn't match the listing. This is in addition to access to chargebacks and other consumer rights

under Australian Consumer Law.

Consumers are also encouraged to report sellers who seek to trade with them off platform

(where protections like the eMBG are not available and scam activity more prevalent). eBay

monitors with AI for potential scams and fake transactions. eBay moves quickly to suspend

offending users where there is a risk of consumer harm.

https://www.ebay.com.au/help/home

https://www.ebay.com.au/help/buying/returns-refunds/return-item-refund?id=4041&st=12&pos=1&query=Return%20an%20item%2

0for%20a%20refund&intent=return&docId=HELP1134

In addition, eBay works closely with various organisations including ACCC’s Scamwatch to both

identify and act on trends in scams and criminal behaviours.

Our commitment to work in partnership with safety regulators to address these issues is

reflected in our participation as an inaugural signatory to the Australian Product Safety Pledge

and our recent launch of the eBay Regulatory Portal. The Product Safety Portal provides

trusted regulators, including the ACCC and Therapeutic Goods Administration with the ability to

take down listings directly where regulators have evidence of a risk to consumer safety. It should

be noted that eBay is the only Australian online marketplace offering this functionality to

regulators.

33. What complaints mechanisms are in place for consumers to report scams or

harmful products to the marketplaces? How effective are these mechanisms?

There are a range of reporting mechanisms for consumers to report scams, unsafe or harmful

products on eBay. Our Customer Service pages allow consumers to report a seller that they

believe is violating our policies. This could include a seller who has:

● Offered to sell an item outside of eBay

● Provided false contact information

● Used abusive or vulgar language

Consumers can also report specific items or listings that they feel violate our policies .

Consumers are directed to a separate reporting flow in the event that the report relates to an

item they’ve purchased (and they need help to get their money back).

As a well known and trusted brand, unfortunately bad actors look to leverage consumers’ trust

in eBay as a means to facilitate email and phone scams (off our marketplace) . Consumers can

report any suspicious phone calls or emails they have received claiming to be from eBay and

we use this information to work collaboratively with authorities. eBay also looks to engage with

our community of users through our various social media channels to ensure people stay safe

when buying online. An example is set out below:

https://www.ebay.com.au/help/account/protecting-account/recognising-phishing-phone-calls-emails?id=4195&st=3&pos=1&query=

Recognising%20phishing%20phone%20calls%20and%20emails&intent=scams&lucenceai=lucenceai&docId=HELP1107

https://www.acma.gov.au/articles/2021-03/scam-alert-acma-warns-ebay-scam-phone-calls

https://www.ebay.com.au/help/policies/member-behavior-policies/report-item-listing?id=4739

https://www.ebay.com.au/help/buying/resolving-issues-sellers/reporting-item-issue-seller?id=4022

https://www.afr.com/politics/federal/regulators-allowed-to-directly-remove-dangerous-ebay-listings-20210521-p57ua3

While we encourage our community of consumers and sellers to report listings and behaviours

that are not allowed under our policies, at eBay we look to address issues at scale through the

development of filters and blocks to prevent consumers being harmed in the first instance.

We have noted in our response at question 12 of the effectiveness of these complaints

mechanisms in removing listings from the eBay marketplace.

34. To what extent are consumers informed about data collection by third-party

sellers and the marketplaces? How is this information presented to consumers?

Consumers are informed about data collection by eBay and third party sellers through the User

Agreement, UPN and Cookies Notice.

User Agreement

eBay’s User Agreement informs the user that:

a. the User Agreement and the UPN apply while using the eBay services;

b. eBay uses information only as described in the eBay UPN; and

c. for a complete description of how eBay uses and protects personal information, the user

should review the eBay UPN, which is clearly linked within the User Agreement.

UPN

eBay users (both buyers and sellers) are provided with a detailed description of eBay’s data

collection practices in eBay’s UPN.

eBay’s UPN is designed to be easily readable by eBay users. The UPN layout features:

a. a clear index at the side of the UPN to enable users to click through to sections that a

user may feel are particularly relevant to them;

b. individual sections under clear headings, containing an overview of the main points with

an expandable section underneath which users can read, by clicking “Learn More”,

significantly more detail in easy to read bullet points; and

c. the option to “expand all” of the sections in the UPN at the outset for a complete viewing

of its contents.

The UPN is ordered in a way to provide users with key information early including the scope of

the notice, the eBay entity responsible for collecting and processing data and the contact details

for privacy concerns, followed immediately by other important information for a user including

what personal data is collected (section 4), the purpose and bases for the processing of their

personal data and categories of recipients (section 5). Section 9 informs users of eBay’s use of

cookies and other technology used to collect and process data and contains a link to eBay’s

Cookie Notice, which contains information about the use of cookies, web beacons and similar

technologies used in connection with the provision of eBay’s services (and how they can be

managed).

Further, sellers are informed that they must comply with applicable data protection laws and

protect the rights of other users as data subjects (section 11).

eBay Policies

Various eBay policies and help pages also reiterate what is stated in the User Agreement and

UPN to the extent they are relevant to the subject matter of the policy or help page. For example

the Signing up for an eBay account help page reiterates that by selecting “create account” the

user agrees to the User Agreement and UPN.

To first register an account with eBay, the sign up flow collects first name, last name, email

address and contains the following wording above the “Create account” button:

By selecting Create account, you agree that you’ve read and accepted our User

Agreement, you’re at least 18 years old, and you consent to our User Privacy Notice

and receiving marketing communications from us.

Footer

The footer of the eBay Home page and each page of the eBay.com.au website contains a link to

the AU User Agreement, User Privacy Notice and Cookies Notice.

Links

Each of the User Agreement, UPN and Cookies Notice contain cross references and links

where applicable to each other.

https://www.ebay.com.au/help/account/signing-ebay-account/signing-ebay-account?id=4191&st=3&pos=1&query=Signing%20up%2

0for%20an%20eBay%20account&intent=Signing%20up%20for%20an%20eBay%20account&lucenceai=lucenceai&docId=HELP107

35. To what extent are consumers able to limit this data collection?

Data is collected for the purposes described in our answer to question 21. Data collection that is

necessary or associated with providing the service cannot be limited on the eBay site. This

includes, for example, data which is necessary to fulfil our contract and provide users with the

service such as product, transaction and payment details.

Some data collection (such as precise location of the user) can be managed by the user in

accordance with the setting of the device they use to access the eBay site and use our services.

Users may be able to limit data collection by cookies used by eBay that are operationally

necessary, performance-related or functionality-related to the provision of our services. This

may be able to be done by the user, using the settings in the browser or device from which the

eBay service is accessed, if this is supported by the particular browser or device. The settings

must generally be made separately by the user for each browser or device used. If a user

chooses to limit data collection in this way they may not be able to use certain eBay services.

Data collection by third parties for advertising related purposes can be limited by the consumer

through the use of opt out provisions for third party cookies.

36. To what extent is consumer data used by third-party sellers or marketplaces to

target consumers?

Use of consumer data by eBay

eBay uses consumer data to provide a more personalised service to its Users. Consumer data

is used to provide targeted marketing and advertising.

In addition to the targeting of users on the eBay Home page as described in answer to question

22 above, eBay uses consumer data to target through marketing channels such as emails, push

notifications and social media platforms. The marketing promotions users see may be targeted

based on a number of things including items they’ve purchased, categories they have shopped

in, items they have “watched” or “saved” and whether they are an eBay Plus member. eBay

users have granular options to unsubscribe from various marketing communications.

eBay may target users with specific offers - for example, eBay may recognise that a user is

accessing the site through a web browser on their mobile device rather than through the eBay

App and accordingly may show those users promotions designed to encourage them to

download the eBay App for a better shopping experience, including access to coupons, price

alerts, and improved delivery tracking.

eBay may also target users with more general prompts and recommendations. For example

eBay may surface item recommendations to buyers based on their previous search history or

queries.

Use of consumer data by third party sellers

Subject to what is said below, eBay cannot comment on the extent to which third party sellers

use consumer data collected by those third party sellers. However, eBay allows sellers to offer

newsletters to users who specifically sign up with the seller for that purpose. Users can elect to

save sellers that they like and once saved, they can click on “subscribe to newsletter” next to

that seller’s profile.

Third party sellers who misuse buyer data obtained as part of a transaction (for example, by

using it to send marketing emails) are in contravention of eBay policy - in particular, in breach of

eBay’s User Agreement, User Privacy Notice (section 20) and SPAM Policy .

Sellers also have the ability to send offers to buyers who have ‘watched’ or added a seller’s item

to their cart. Further information can be found on this help page under the heading ‘Sending

offers to interested buyers’.

Use of consumer data by both sellers and eBay

eBay uses consumer data to facilitate its sellers’ display advertising on the eBay site. eBay may

target those seller advertisements to its users based on consumer data that eBay has collected.

eBay also facilitates sellers displaying their listings in a targeted manner through eBay’s

Promoted Listing tool. The Promoted Listings tool allows a seller’s listing to be displayed more

prominently to a buyer in response to their search query or to appear as a “suggested” or similar

promoted item alongside another listing the buyer is viewing.

37. To what extent (if at all) is a consumer’s data used in a way that affects the

price offered to the consumer?

As a pure third party online marketplace, third party sellers on eBay control the price offered on

the items they choose to list and sell.

As we have noted previously in this submission, all eBay sellers are given access to the

Terapeak Research and Insights tool which provides historical data on selling trends on eBay. At

a seller’s discretion, Terapeak may be used to assist in setting prices for items they list on eBay.

If a seller is listing an item on eBay that has previously been sold, during the listing flow, a

suggested price for that item will also be provided. This will be based on the condition identified

by the seller and the average selling price of a similar item.

As mentioned above, eBay does use data to target users and in doing so it may offer certain

targeted users discount coupons to apply that will affect the price a user pays for items on the

eBay site. Sellers can also send offers to interested buyers as referred to above in response to

question 36.

https://www.ebay.com.au/help/policies/member-behavior-policies/spam-policy?id=5033&st=3&pos=1&query=Spam%20policy&intent

=spam&context=DEFAULT_BUYER&lucenceai=lucenceai&docId=HELP1558

Thank you once again for the opportunity to participate in this consultation. If you wish to

discuss these matters further, please feel free to contact the writer via

Yours sincerely,

Luke Aitken

Head of Government Relations and Public Policy

eBay Australia and New Zealand