ABSTRACT
In this chapter, serving as a background for further discussion on the collective redress systems in particular jurisdictions, very brief terminological remarks are presented. In the opinion of the author, it is not possible to examine the concept of collective redress without a short reference to the American class action system. Thus, the EU's and the US's approaches are compared to highlight the distinctions between these two concepts. Further, this chapter examines the long and bumpy route to establishing a legislative framework for collective consumer redress in the EU. It starts from the critical assessment of the first injunctive measures introduced in late 1990s, with focus on challenges with consumer law enforcement under Directive 2009/22/EC, followed by an examination of the controversial Proposal for the Representative Actions Directive and ending with an evaluation of the existing framework introduced by the final version of the Representative Actions Directive.
