This chapter offers a thorough examination of the elements of the vulnerable consumer standard in the Unfair Commercial Practices Directive (UCPD). Under the class approach, certain categories of consumers e.g. the poor or the illiterate are identified as vulnerable. The examination of drafts of the Directive reveals a more sophisticated version of the vulnerable consumer than the diluted version of the UCPD. The elderly is a group that is often cited as being vulnerable, yet the issues surrounding vulnerable consumers are complicated. Teenagers may be quite sophisticated consumers in some markets but more vulnerable in others, such as financial services. Vulnerability due to a temporary circumstance cannot be included in the average vulnerable standard. Twigg-Flesner et al. mention tourists or asylum seekers as potentially credulous categories due to their language skills, but generally think that it is difficult to find groups that are clearly identifiable as vulnerable.