14. Article 2 provides for different parts of the Order (and in some instances different articles) to come into force at different times.
15. The draft Order refers to ‘Providers’ throughout. Articles 3, 4 and 5 control who that refers to in each Part or Article. Article 3 provides a very wide application which is limited by the application of the de minimis exemptions in Article 4 and exceptions in Article 5.
16. The de minimis exemption for Part 3 is somewhat different and more complex than that which applies to other parts. This is due to the importance of maintaining stability in the participants in the service quality remedy. Brands not subject to this remedy will not be able to volunteer to be included in it. In part this is due to a concern about Brands with few PCAs or BCAs being able to generate sufficiently robust survey results. Even where a Brand has sufficient scale to participate in the remedy it will still take time to be included in the surveys and for customer data
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