.eu registrar Code of Conduct

EURid's draft code of conduct for its accredited registrars is out.
The code will not be binding to them: Registrars will adhere on a voluntary basis (they will be able to display a logo which shows their adhesion). This proposed set of rules also includes a duty of cooperation between .eu registrars.
EURid invites all interested parties to review the draft document and send comments by email to conduct [at] eurid.eu before February 19.

Spontaneous remarks:
- The definition of "domain name" is slightly different in this document (although this may not have any legal consequences)
- "The registrar will ensure that the country code used during registration is the correct one" (2.2). This is a good idea, since it seems that a defendant in several .eu ADR cases was not eligible to register. Nevertheless, I wonder how registrars will enforce this rule. Will they have to verify before the registration, or can it be afterwards?
- Section 2.3 on acknowledgement of orders seems redundant with the provisions of the EC Directive of June 8, 2000
- With sections 2.5 and 2.6, there is a new tool to prevent warehousing (but recall this code is not binding)
- Section 3 on Service policy principles seems more inspired by EU consumer rules than by trade rules (I hope it will not hinder B2B transactions on domain names). Section 5 recaps the major principles of EU protection of personal data
- A board of conduct will be competent in case of complaints (will it be possible for registrants to lodge a complaint?)