Ref. Ares(2020)1335408 - 03/03/2020
Meeting on 17th January 2020 with the EU Public Policy Manager of Google – notes
Please see below the notes from the meeting of E4 (
) with the EU Public
Policy Manager of Google which took place on 17th of January.
Issues raised by Google:
Lack of clarity whether certain ad products fall under the scope of the P2B
Regulation. Difficulties with differentiation between ads and ranking influenced by
direct or indirect remuneration.
Google seeks guidance on the above issue including some examples. Ads business and search
business are two different and separate business models driven by different technologies within
Google (see Google submission paper in response to the EC consultation).
The EC standpoint is that the ranking article mentions the possibility to influence ranking against
direct or indirect remuneration. Hence, on the one hand, there are ranked sponsored search results
covered by the P2B and, on the other hand, ad content managed by third party intermediaries such
as banner ads that pop out and do not fal under P2B. There might be tools in the middle that are stil
subject to discussions.
Specific examples mentioned by Google:
• Confusion whether the ads on top of organic search fal under P2B.
The EC standpoint is that ads popping out are separate tools.
• Apps suggested in app stores on the landing page without introducing a search query.
EC referred to the definition of ranking is and whether it must be a direct response to a query (in
search engines) or just a given relative prominence. EC considers that the way of presentation of
apps on the landing page must be explained, as must e.g. manipulation detecting filters, albeit not in
too much detail in order not to spoil the very purpose of such filters.
How does Google comply?
• There is already a webpage called ‘How Search Works’ that presents an explanation on how ads
work and the difference between an organic search. Additionally, there is a detailed document
called ‘General Guidelines’ that includes more technical information.
• Google underlined that it is also in the search engine’s interest to give users clarity on how
search works in order to allow them to rank successfully.
• Codes of Conduct – Google is already part of some such as on disinformation guidelines.
• To consider in view of P2B compliance – how to make the information available for the users in
a publicly and easily accessible location (e.g. a link on the landing page).