Slap a label on it! Making it easier for consumers to shop for Internet services

Remarks by Brad Callaghan, Associate Deputy Commissioner of the Policy, Planning and Advocacy Directorate; and Jonathan Fonberg, Senior Behavioural Scientist, Behavioural Insights Unit 

Opening statement at CRTC public hearing re: Telecom Notice of Consultation CRTC 2024-318

June 13, 2025

Gatineau, Quebec

(As prepared for delivery)

Good afternoon, Mr. Chair, Commissioners and Commission staff. Thank you for the opportunity to appear here today on unceded Algonquin Anishinabeg land just north of the Kichi Zibi.

My name is Brad Callaghan, and I am the Associate Deputy Commissioner of the Policy, Planning and Advocacy Directorate at the Competition Bureau of Canada.

Let me begin by introducing the members of our panel. To my right is:

• Ben Klass: Competition Law Officer, Policy, Planning and Advocacy Directorate; and
• Derek Leschinsky: Senior Counsel, Competition Bureau Legal Services.

To my left is:

• Jonathan Fonberg, Senior Behavioural Scientist, Behavioural Insights Unit; and
• Émilie-Ève Gravel, head of the Competition Bureau’s Behavioural Insights Unit.

The Competition Bureau is an independent law enforcement agency that protects and promotes competition for the benefit of Canadian consumers and businesses. We are an evidence-based agency we’re not influenced by commercial interests, but by the public interest just like the CRTC.

We hope that our participation in this consultation will help to deliver outcomes that serve the public interest by creating the conditions for competition.

Telecommunications services like home internet and mobile connectivity have become an essential part of modern life. Since the pandemic, Canadians across the country have come to rely on their connections more than ever before to stay in touch with family and community, to learn, work, play, and to do business.

Policies promoting marketplace competition are helping get us to a place where most people have access to a range of innovative services that meet their needs at affordable prices.

At the same time, your consumer codes for wireless, internet, and television services have helped empower consumers to make choices between services and providers on their own terms.

Despite these positive steps, there are signs telling us there’s still work to be done and competition is key to achieving your policy objectives.

So, as technology, markets, and patterns of communication evolve, we see this consultation as an opportunity to build on past successes and keep the momentum going.

In our submission, we’ve shared several recommendations that we hope will help improve competitive dynamics and consumer choice in Canada’s telecom markets.

Our recommendations are grounded in the general principle that good information and freedom from barriers to switching are key ingredients in the recipe for competition. When either or both of these components are lacking, it makes room for the exercise of market power, which can be harmful for consumers and the economy more broadly.

To develop our input, we conducted desk research, consulted with stakeholders including other domestic and international regulators and engaged our behavioural insights experts, who are here with us today, to sharpen the focus on providing evidence-based best practices for empowering consumers.

So, with that in mind, I’ll now briefly outline our recommendations and some of the key ideas why we think adopting them will help.

First, we support the adoption of a ‘nutrition label’ format for providing customers with information.

Four out of five participants in the CRTC’s public opinion research felt that ‘standardized information in a recognizable format, like the nutrition label but for home Internet services’ would be beneficial.

We agree the label is a good idea and Canadians are already familiar with it: their experience in the food products sector shows that labels are an effective, adaptable tool for conveying complex yet crucial information about goods and services.

From a competition perspective, enabling people to more easily compare services and providers gives them the power to make choices based on their own specific needs and circumstances. When consumers have good information that they can act on to switch, providers will work harder to make sure people’s needs are being met.

The US Federal Communications Commission (FCC) has already put in the legwork to adapt the nutrition label for the fixed and mobile broadband services. We believe that the record of their extensive rulemaking process represents a helpful resource to consult as the CRTC develops its own ‘made for Canada’ version of the label.

So what does a ‘made for Canada’ label look like?

For the most part, we think it should look a lot like the FCC’s label information about price, performance, and other important service characteristics is presented in a format that’s already familiar for Canadian consumers from their experience in the grocery aisle with just a few key differences.

In our view, the monthly price on a ‘made for Canada’ label should show an ‘all-in’ price that includes all fixed and obligatory charges or fees as opposed to the approach favoured by the FCC where a baseline monthly price is followed by additional monthly fees. The reason is that Canada’s Competition Act prohibits ‘drip pricing’. Keeping the label consistent with the drip pricing provisions means making sure that the carriers can not be permitted to display a price that is unattainable because of additional fixed and obligatory charges or fees that drive up the price consumers ultimately pay for their services.

Adopting an ‘all-in’ approach to pricing would help the label to work in harmony with the Competition Act’s provisions on drip pricing.

Similarly, all relevant ads and information contained in policies and disclaimers must be consistent with information in the label. To the extent that the label refers or links to disclaimers, they cannot be used or relied upon to restrict, contradict, or negate any marketing messages, or otherwise cure misleading or deceptive marketing practices.

Overall, this approach would help keep information simple, relevant, and it would facilitate apples-to-apples comparisons.

Second, we think the label would benefit wireless phone customers and competition in that market, too.

Like home internet services, wireless phones are essential for nearly all Canadians. CCTS and CRTC data show that Canadians have similar issues with both services, too.

Every Canadian wireless network operator also offers home Internet – meaning that they will already be developing labels as a result of this proceeding.

From our perspective, extending the labels’ application to wireless phone services could deliver significant benefits for minimal additional cost. Doing so would help to simplify and harmonize the consumer information environment in general while avoiding the need to duplicate efforts down the road.

Third, we think the labels would be especially beneficial for customers who are actively shopping, and for subscribers whose contracts are about to expire.

Dr. Fonberg will explain how we can think about making sure the labels are as useful for consumers as possible.

[Jonathan Fonberg, Senior Behavioural Scientist]

Thank you.

Consumers are less likely to engage with information if the effort required to identify and understand that information is high.

That means difficulties in accessing critical information about broadband plans and alternatives can create barriers to switching.

Our recommendations draw on key principles and best practises from behavioural science.

They aim to empower consumers by reducing the effort required to identify and understand critical information; thereby reducing barriers to switching.

To that end, these recommendations address both the format and availability of the label.

First, the label design should allow consumers to quickly grasp key information. It should be easily accessible and comprehensible.

This is intended to reduce the effort required by customers to interpret complex plan information.

But beyond what’s in the label, when and where it’s found is also important.

We recommend that it be widely available anywhere specific plan information is displayed. We are also asking that the label be included in notices sent to customers whose contracts are set to expire.

This will reduce the need for customers to search for key details buried in the fine print, making the process more convenient and increasing their chances of engaging with it.

These recommendations are intended to ensure that customers will be able to easily access the label when they need it the most, maximizing its benefit.

[Brad Callaghan, Associate Deputy Commissioner]

Thank you, Dr. Fonberg.

The CRTC has taken important steps in recent years to empower consumers in their relationships with their service providers. Ensuring that phone numbers are portable, placing limits on contract length, and unlocking devices are just some of the actions the CRTC has taken to foster competition in the marketplace for the benefit of consumers and the economy.

The Competition Bureau is pleased that the CRTC continues to build on these achievements. A broadband nutrition label can put consumers in the driver’s seat of the switching process and improve competition in telecommunication markets. With clear, standardized information to compare their options, consumers can take advantage of competition more easily, and companies will compete harder to keep them.

We’d like to thank the Commission for the opportunity to participate in these proceedings. We will endeavour to answer any questions you may have.