Europe and USA: my personal market comparison

While I have already announced I’m moving to London, I don’t want to give the idea that I don’t trust Europe. One of my acquaintances, an eurosceptic, thought it was apt o congratulate me for dropping out of Europe when I announced my move, but that couldn’t be farthest from my intention. As I said already repeatedly now, my decision is all to be found in my lack of a social circle in Dublin, and the feelings of loneliness that really need to be taken care of.

Indeed, I’m more than an Europeist, I’m a Globalist, in so far as I don’t see any reason why we should have borders, or limitations on travel. So my hope is not just for Europe to become a bigger, more common block. Having run a business for a number of years in Italy, where business rules are overly complicated, and the tax system assumes that you’re a cheater by default, and fines you if you don’t invoice enough, I would have seriously loved the option to have an “European business” rather than an “Italian business” — since a good chunk of my customers were based outside of Italy anyway.

This concept of “European business”, unfortunately, does not exist. Even VAT handling in Europe is not unified, and even though we should have at least a common VAT ID registration, back when I set up my business, it required an explicit registration at the Finance Ministry to be able to make use of the ID outside of Italy. At the time, at least, I think Spain also opted out to registering their VAT IDs on the European system by default. Indeed that was the reason why Amazon used to the run separate processes for most European business customers, and for Italian and Spanish customers.

Speaking of Amazon, those of you reading me from outside Europe may be surprised to know that there is no such thing as “Amazon Europe”, – heck, we don’t even have Amazon Ireland! – at least as a consumer website. Each country has its own Amazon website, with similar, but not identical listings, prices and “rules of engagement” (what can be shipped where and for which prices). For the customers this has quite a few detrimental effects: the prices may be lower in a country that they may not usually look at the store of, or they may have to weight the options based on price, shipping restrictions and shipping costs.

Since, as I said, there is no Amazon Ireland, living in Dublin also is an interesting exercise with Amazon: you may want to order things from Amazon UK, either because of language reasons, or simply because it requires a power plug and Ireland has the same British plug as the UK. And most of the shipping costs are lower, either by themselves, or because there are re-mailers from Northern Ireland to Dublin, if you are okay with waiting an extra day. But at the same time, you’re forced to pay in GBP rather than Euro (well, okay not forced, but at least strongly advised to — Amazon currency conversion has a significantly worse exchange rate than any of my cards, especially Revolut) and some of the sellers will actually refuse to send to Ireland, for no specific reason. Sometimes, you can actually buy the same device from Amazon Germany, which will then ship from a UK-based storehouse anyway, despite the item not being available to send to Ireland from Amazon UK. And sometimes Amazon Italy may be a good 15% cheaper (on a multiple-hundreds euro item) than Amazon UK.

So why does Amazon not run a global European website? Or why doesn’t an European-native alternative appears? It looks to me like the European Union and its various bodies and people keep hoping to find European-native alternatives to the big American names all the times, at least on the papers, probably in the hope of not being tied to the destiny of American with what comes down in the future, particularly given how things have gone with the current politics on all sides. But in all their words, there does not appear to be any option of opening up opportunities for creating cross-Europe collaboration on corporations.

The current situation of the countries that make up Europe and the States that make up the USA, is that you are just not allowed to do certain types, or levels of business in all the countries without registering and operating as a company in that country. That is the case for instance of phone operators, that get licenses per country, and so each operates independent units. This becomes sometimes ludicrous because you then have Vodafone providing services in about half of Europe, but with such independent units that their level of competence for instance on security and privacy is extremely variable. In particular it looks like Vodafone Italy still has not learnt how to set up HTTPS correctly, and despite logging you in a TLS-encrypted connection, it does not set the cookie as secure, so a downgrade is enough to steal authentication cookies. In 2017.

If you remember, when I complained about the half-baked roaming directive results, I have suggested that one of my favourite options would be to have a “European number” — just give me a special “country code” that can be replaced by any one member’s code, and the phone number is still valid, and appears local. This is important because, despite the roaming directive allowing me to keep my regular Irish (for now) SIM card on my phone while travelling to either UK or Finland, it prevents me from getting a local phone number. And since signing up for some local services, including sometimes free WiFi hotspots from various cafes and establishment, relies on being able to receive a local SMS, it is sometimes more of an hindrance than a favour.

Both Revolut and Transferwise, as well as other similar “FinTech” companies have started providing users with what they call “borderless” accounts: Euro, Sterling and Dollar accounts all into one system. Unfortunately this is only half of the battle. Indeed, while I welcome in particular Revolut’s option of using a single balance that can provide all the currencies in a single card is a great option. But this only works to a point, because these accounts are “special” — in particular the Revolut Euro account is provided with a Lithuanian IBAN, but a UK BIC code, which makes a few system that still expect both throw up. And this is not even going into how SEPA Direct Debit just does not work: my Italian services can only debit an Italian bank, my Irish services can only charge an Irish bank, and my one French service can only charge a French bank. Using credit cards via VISA has actually better success rate for me, even though at least Vodafone Italy can only charge a specific one of my credit cards, rather than any of them. Oh yeah and let’s not forget the fact that you just can’t get your salary paid into a non-Irish bank account in Ireland.

Banks in Europe end up operating as country-wide silos, to the point that even Ulster Bank Republic of Ireland cannot (at least, can no longer) provide me with an Ulster Bank Northern Ireland bank account — or to be precise, cannot act on my already-existing foreigner bank account that is open in Northern Ireland. And because of all these things happening, the moment I will actually move to London I’ll have to figure out how to get a proper account there. I’m having trouble right now opening an account there already not because I don’t have the local tax ID but because they need proof of employment from a UK company, while I’m still employed by the Irish company. Of the same multinational. Oh my.

You could say that banks and telcos are special cases. They are partial monopolies and there are good reasons why they should be administered on a country-by-country basis. But the reality is that in the United States, these things are mostly solved — plenty of telco stuff is still pretty much local, but that’s because of network access and antitrust requirements, as well, to a point, the need of building and servicing local infrastructure (a solution to this is effectively splitting the operation of the telco from the provider of physical infrastructure, but that comes with its own problems). But at the very least, banking in the US is not something that people have to deal with when changing State, or having to work with companies of other states.

These silos are also visible to consumers in other forms, that may not be quite obvious. TV, movie and similar rights are also a problem the same way. Netflix for instance will only show a subset of the programming they have access to depending on the country you’re currently located in. This is because, except for the content they produce themselves, they have to acquire rights from different companies holding them in different countries, because different TV networks would already have secured rights and not want to let them broadcast in their place.

I brought up this part last, despite being probably the one most consumers know or even care about, because it shows the other problem that companies trying to build up support for Europe, or even to be started as Europe-native companies, have to deal with. TV networks are significantly more fragmented than in the USA. There is no HBO, despite Sky being present in a number of different countries. There is nothing akin to CNN. There are a number of 24-hours news channels that are reachable over more-or-less freeview means, but the truth is that if you want to watch TV in Europe, you need a local company to provide you with it. And the reason is not one that is easy to solve: different countries just speak different languages, sometimes more than once.

It’s not just a matter of providing a second channel in a different language: content needs to be translated, sometimes adapted. This is very clear in video games, where some countries (cough Germany cough) require cutting content explicitly, to avoid upsetting something or someone. Indeed, video games releases for many platforms, in the past at least including PC, but luckily it appears not the case nowadays, end up distributing games only in a subset of European languages at a time. Which is why I loathed playing Skyrim on the PlayStation 3, as the disk only includes Italian, French and German, but no English, which would be my default option (okay, nowadays I would probably play it in French to freshen up my understanding of it).

For American start-ups – but this is true also for open source project, and authors of media such as books, TV series or movies – internationalization or localization are problems that can be easily shelved for the “after we’re famous” pile. First make the fame, or the money, then export and care about other languages. In Europe that cannot possibly be the case. Even for English, that in the computer world is still for now the lingua franca (pun intended), I wouldn’t expect there would be a majority of users happy to use a non-localized software, particularly when you consider as part of that localization the differences in date handling. I mean, I started using “English (UK)” rather than the default American for my Google account years ago because I wanted a sane date format in Gmail!

All of this makes the fragmented European market harder for most projects, companies, and even ideas to move as fast as the American or (I presume, but have not enough detail about it) the Chinese market, in which a much wider audience can be gained without spending so much effort to deal with cross-border bureaucracy and cross-culture porting. But let me be clear, I do not think that the solution is to normalize Europe onto a single language. We can’t even do that for countries, and I don’t think it would be fair to anyone to even consider this. What we need is to remove as many other roadblocks as it’s feasible to remove, and then try to come up with an easier way to fund translation and localization processes, or an easier way to access rights at a Union level rather than on a country-by-country basis.

Unfortunately, I do not expect that this is going to happen in my lifetime. I still wish we’ll end up with a United Federation of Planets, at the end of the day, though.

One thought on “Europe and USA: my personal market comparison

  1. This is a topic I am very passionated about, having lived in Italy, Germany, Ireland, and France I have experimented most of the problems you describe. However I am slightly more optimistic than you are.Regarding banking there are issues, but they are mostly due to blatant ignorance of service providers, the population and the fact most banks ignore European rules. That said my French girlfriend lived and worked for 7 years in Italy using a French account, simply because her employer and the service providers she worked with used the IBAN. I am in the middle of moving back to Italy and I could debit all my services on my French bank account, no issues so far.I had issues in the past and I was forced to open bank accounts in Germany, France, and Ireland but things are changing. The changes are slow but really there is no good reason for that. Today an IBAN is enough to do a wire transfer or SEPA Debit. The BIC should not be required anymore. As more people becomes aware there is no reason to prevent using bank accounts from other countries things will improve. For example, I had to go through a different procedure to send money to an Italian bank account from a French one. That was a clear violation of laws approved years ago but in the last months Societe Generale fixed that, so that I can send money to Italian and other European bank accounts as I can do with French ones.Regarding mobile phones, there are issues. For example I cannot call an Italian free toll number from abroad. Not even if I was willing to pay it. It just does not work if you call from abroad. However beside that you can use data roaming for free. My provider offered me 10GB per month to be used in Europe for the last couple of years already. We are getting there. I think this is a huge benefit for people.Doing business with other European countries can still be a little more complicated. In France I had to fill out a form (with 2-3 fields) every time I invoiced a non-French but European business. It took me around 10 seconds. In Italy you have to fill out intrastat forms, and I guess it is a bit more complicated.I think there are still barriers due to the languages and the fact that people does not move that much around Europe. French go to Quebec, very few go to Germany because they cannot speak German or English. So not so many people experience the practical difficulties of moving within Europe and it takes time to build awareness and improving things. On the other hand we had millions of Erasmus students and at least one million Europeans that were born because of Erasmus. I think they will be the ambassadors for Europe and they will help smooth things.Personally I am not a globalist, I firmly believe in Europe. I think we share core values and a way to intend our societies. We can work together and make our relations stronger, and our countries more interconnected. Getting rid of UK will be a blessing, in my opinion, and it will help us moving faster and in a better direction.


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