Package travel and linked travel arrangements: make the protection of travellers more effective and simplify and clarify certain aspects

The Swedish Aviation Industry Group (SAIG) is a non-profit making industry association which promotes, protects and ensures that its member companies are not neglected with respect to political issues and lobbies for the continued survival and well-being of the Swedish air transport industry.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

There is a major imbalance between the responsibilities that a package tour operator already has under the 2018 Package Travel Directive today and the Consumer protection in other sectors as well as within the travel industry itself.

V Praze dne 13. března 2024 Stanovisko k návrhu směrnice Vážení, dovolujeme si reagovat na návrh úpravy směrnice EU – souborné služby pro cesty. Po důkladném prostudování tohoto návrhu shledáváme několik značně problematických bodů. V našich připomínkách se chceme vyjádřit především ke dvěma bodům, které shledáváme za nejzávažnější.

Filed in Czech · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

IFTTA (International Forum of Travel and Tourism Advocates) is a stakeholder in promoting good legislation in travel and tourism. The main motivation of IFTTA for giving feedback to the EC regarding the PTD revision is to drive attention to its shortcomings in terms of the law. IFTTA is planning to provide EC with a detailed position paper in which it will draw attention to the real problems of the PTD.

First of all, we would like to express our gratitude for the opportunity to comment on the legislative act adopted by the Commission. For more than 10 years, Flightright has been helping air passengers to enforce their rights. As the market leader in our segment, we are committed to giving people access to justice by making sure that existing claims are successfully enforced.

Proposal for new EU rules on package travel: Visita strongly criticises the proposal to limit advance payments to 25 % for package travel and linked travel arrangements Visita considers that the conditions for exemption from the restriction on advance payments need to be developed more clearly.

Filed in Swedish · English published by the European Commission

CarTrawler is the leading B2B technology provider of car rental solutions to the global travel industry and employs over 400 people almost all of whom are based in Ireland. We operate a three-sided online marketplace whereby our platform enables airlines and other partners to offer car rental to their customers as an ancillary product.

13 March 2024 European Commission Directorate-General for Justice and Consumers (JUST) Feedback on the proposal for a directive of the European Parliament and of the Council amending Directive (EU) 2015/2302 to make the protection of travellers more effective and to simplify and clarify certain aspects of the Directive.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Booking.com is a leading global travel company, founded and headquartered in the Netherlands, with a mission to make it easier for everyone to experience the world. Consumers are increasingly looking for flexible and diverse options when planning their travel/holidays.

The Fédération Internationale de lAutomobile European Bureau (FIA EB) strongly supports the European Commission proposals for a revised Package Travel Directive (PTD) and passenger rights regulations. Travellers will benefit from improved rights and strengthened consumer protection. Below, we outline some recommendations to further enhance these proposals. Detailed feedback can be found in attached file.

EU Consumers often book their holidays through pre-arranged/customized packages. These contracts are governed by the Package Travel Directive (PTD). Despite being an important consumer protection instrument, the Thomas Cook bankruptcy and the COVID-19 crisis revealed shortcomings of the PTD which need to be corrected to ensure high levels of consumer protection, also during crisis.

EU Commission Rue du Luxembourg 1000 Bruxelles, Belgium 13th March 2024 Statement by Aktionsbündnis Tourismusvielfalt (ATV) on the Commission's proposal for a revision of the Package Travel Directive European Honourable Members of Parliament, Aktionsbündnis Tourismusvielfalt (ATV) is a coalition of 27 tourism industry associations representing all areas of the diverse tourism industry.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Dear Sir, Madam, Please find attached the opinion of the Federal Chamber of Labour (BAK) on the Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Directive (EU) 2015/2302 in order to improve the protection of travellers and simplify and clarify certain aspects of the Directive (COM(2023) 905 final). Yours sincerely,

Filed in German · English published by the European Commission

Matkailu- ja Ravintolapalvelut MaRa ry the Finnish Hospitality Association (MaRa) is a leading national trade and labour market association in the hospitality industry in Finland. It represents a wide range of companies in hospitality sector for example hotels and other accommodation services and adventure services.

This response represents easyJet Groups views. easyJet Group is comprised of easyJet holidays and easyJet (referred to as easyJet airline). easyJet holidays is the fastest growing tour operator in the UK, offering great-value beach, city and lakes package holidays to more than 100 destinations across Europe, directly through its website and through over 3000 travel agent partners.

Gemeinsame Verbändeposition 22. Februar 2024 Revision der Pauschalreiserichtlinie E-Mail eintragen Durchwahl eintragen Generell Die Pauschalreise stellt heute schon ein mit einem umfassenden Verbraucherschutz ausgestattetes Reiseprodukt dar.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Package holidays are already the safest form of travel. There is no other industry where customers benefit from comparable protection. We urge for moderation in the PTD revision to not jeopardise the competitiveness of the European package holiday.

The Finnish Competition and Consumer Authority (FCCA) enforces the PTD in two different roles. The Consumer Ombudsman of the FCCA is a single liaison office under general consumer protection legislation in Finland. The primary duty of the Consumer Ombudsman is to ensure that the marketing, contract terms and commercial practices of organizers are in line with the PTD for the collective benefit of consumers.

Summary of our opinion on the Commission’s rapid efforts to further improve the protection of travellers, the simplification and clarification of certain definitions and the timely incorporation of improvements in these areas of life in the light of the experience of the past crises, is warmly welcomed by the ÖAMTC.

Filed in German · English published by the European Commission

ECTAA the European Travel Agents' and Tour Operators' Association, would like to comment on the European Commission's proposal to revise the Package Travel Directive (PTD), published on 29 November 2023. This directive is of crucial importance for travel agents and tour operators as main providers of package travels.

ANWB is positive about the proposal for a new package travel directive. Consumers will benefit. However, there is still too little consistency between the rules on package travel and those on single transport tickets. For example, the traveller with a single ticket is still in danger of being left outstanding in the event of an airline going bankrupt, while that risk is covered in the case of a package holiday.

Filed in Dutch · English published by the European Commission

Emirates Holidays (UK) Limited is a company incorporated in England. However, it trades out of the Republic of Ireland and also has subsidiary businesses trading in Germany and Denmark. Therefore, it is interested in the proposed amendments to the Package Travel Directive (PTD) and sets out its comments below accordingly.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The two purposes of the PTD are to improve consumer rights and the internal market. One important tool is the obligation for organisers to secure customer payments against insolvency. This proposal and the covid-19 pandemic further emphasize the importance of insolvency protection. Sunweb Group fully supports this purpose.

ERA position on the EC Passenger Mobility Package Ref. Ares(2024)1946891 - 13/03/2024 March 2024 The adoption of the Passenger Mobility Package is a step forward in updating the relevant EU regulations governing passenger rights, but much more needs to be done to provide clarity for both airlines and consumers alike. The air passenger rights framework needs an urgent revision, having not been updated since 2013.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ABTA welcomes the opportunity to provide feedback to the European Commissions review of the Package Travel Directive (PTD). Six years after the adoption of the Regulations, and with the industry having gone through the greatest crisis that it has ever faced in the pandemic, ABTA acknowledges that the Commission is seeking to address the challenges around refunds, vouchers, advance payments and insolvency protection…

European insurers fully support the EUs objectives of making the protection of travellers more effective and to simplify and clarify certain aspects of the original Directive. This is especially relevant in the wake of the numerous challenges faced by the travel industry after the bankruptcy of the travel group Thomas Cook, and during the COVID-19 pandemic.

Honourable Members of Parliament, The Aktionsbündnis Tourismusvielfalt (ATV) is a coalition of 27 tourism industry associations representing all areas of the diverse tourism industry. We have set ourselves the goal of preserving tourism as a whole and achieving fair promotion for every market participant in the industry in order to ensure that the network remains a unified entity in the future.

France Assureurs and its members welcome the revision of the Package Travel Directive. We share with the European Commission the same observations made after Covid-19, when many consumers saw their trips cancelled due to travel restrictions implemented by the States.

The response to the consultation has been prepared by the five Nordic travel industry associations: Svenska Resebranschföreningen (SRF), VIRKE, SMAL, Rejsearrangører i Danmark (RID) and Danmarks Rejsebureau Forening (DRF).

Luxair S.A., Luxembourg Airlines – Comments on the Revision of the PTD Directive EU2015/2305 Revision of the Package Travel Directive (PTD), EU2015/2302 General The important and relevant proposed amendments to the PTD for Luxair are: - Improve the protection of travellers’ advance payments (limit to 25 %) and their right to a swift refund of payments already made in the event of cancellations, including in times of…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Návrh směrnice, kterou se mění směrnice (EU) 2015/2302 s cílem zefektivnit ochranu cestujících a zjednodušit a vyjasnit některé aspekty směrnice – připomínky Hospodářské komory ČR Hospodářská komora vítá možnost vyjádřit se k návrhu směrnice a níže přikládá připomínky svých členů z oblasti cestovního ruchu.

Filed in Czech · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The attached paper contains EPF's feedback to the proposal for a revision of the Package Travel Directive. In EPF's view, the proposed amendments to the PTD bring many improvements: Overall, clearer rules and reduced legal uncertainty; Strengthened insolvency protection; Clarification of passengers right to self-cancellation; Clearer rules on vouchers; Roles of different actors clarified, B2B rules help to ensure a…

The European Commission presented the Proposal for a Directive amending Directive (EU) 2015/2302, which modifies certain provisions of the rules on package travel and linked travel arrangements, with the aim of expanding the rights of travellers, and improving their experience and access to information.

Expedia Group feedback on the review of the Package Travel Directive (PTD) Expedia Group welcomes the Commission's initiative to review Directive 2015/2302 on package travel and linked travel arrangements (PTD) nearly four years on from the outset of the COVID-19 pandemic.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

FITE contribution to the European Commission consultation on the Package Travel Directive 4 December 2023 – 13 March 2024 The FITE gathers more than 20 National Equestrian Tourism Organizations (NETOs) within the European Union but also outside Europe: in Canada, China, Côte d’Ivoire… Some of the NETOs are national sport federations such as Belgium, Germany, Spain or France.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

FFE contribution to the European Commission consultation on the Package Travel Directive 4 December 2023 – 13 March 2024 The French Equestrian Federation (FFE), the French sport federation for equestrian sports with 9500 equestrian holdings and more than 700 000 licence holders, welcomes the revision of the Package Travel Directive.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

eu travel tech recommendations: 1. Levelling the Playing Field for Consumer Protection: It is imperative that negotiators prioritise harmonising consumer protections across all aspects of travel, ensuring that standalone services, such as flights, are subject to similar mandatory insolvency protection schemes as travel packages.

Europos Komisijai 2024-03-05 Nr.2024003 KOPIJA LR Teisingumo ministerijai LR Ekonomikos inovacijų ministerijos Ekonominės plėtros grupei DĖL EUROPOS PARLAMENTO IR TARYBOS DIREKTYVOS, KURIA SIEKIANT UŽTIKRINTI VEIKSMINGESNĘ KELIAUTOJŲ APSAUGĄ IR SUPAPRASTINTI BEI AIŠKIAU IŠDĖSTYTI TAM TIKRUS DIREKTYVOS ASPEKTUS IŠ DALIES KEIČIAMA DIREKTYVA (ES) 2015/2302 PASIŪLYMŲ Lietuvos turizmo asociacija - vienijanti nuo…

Filed in Lithuanian · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

With currently more than 21 million members, ADAC e.V. is the largest automobile club in Europe and the second largest in the world. The four letters in its name stand for an association which offers its members assistance, protection and advice around the clock and is a powerful stakeholder on all mobility issues.

Filed in German · English published by the European Commission

01 POSITION PAPER Ref. Ares(2024)1342532 - 21/02/2024 POSITION PAPER Position Paper of the German Insurance Association (GDV) Lobby Register No. R000774 on the Commission’s Proposal for a Directive revising Directive (EU) 2015/2302 on package travel and linked travel arrangements (COM (2023) 905 final) Contents German insurers are grateful for the opportunity to comment on the Commission’s proposal for a Directive…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Superior Council of Self-Employed Persons and SMEs considers that the proposal for a revision of Directive 2015/2302 on package travel and linked travel arrangements does not sufficiently address the difficulties faced by organisers and retailers and even risk further undermining their competitive position. Further weakening of these actors would also be detrimental to travellers.

Filed in French · English published by the European Commission

Viagens Organizadas Proposta de alteração da Diretiva Rosário Tereso [email removed] Viagens Organizadas Proposta de alteração da Diretiva (UE) 2015/2302 relativa às viagens organizadas e serviços conexos COM/2023/905 final Apreciação na generalidade A Diretiva (UE) 2015/2302 relativa às viagens organizadas e aos serviços de viagem conexos (doravante, Diretiva 2015/2302), propunha-se, atendendo à evolução do…

Filed in Portuguese · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The CNA responds to this consultation via the CNA Tourism and Trade, which represents businesses operating in the tourism sector throughout the country and which contribute to attractiveness and value for the regions and make them more user-friendly.

Filed in Italian · English published by the European Commission

A positive development but the fact that the airlines and other means of transport within a package do not have to sign insolvency insurance will always give rise to problems for the organisation. The difference between countries in relation to insolvency insurance also leads to abuses (unfair competition). There is a need for uniformity within all Member States.

Filed in Dutch · English published by the European Commission

Suomen Yrittäjät the Federation of Finnish Enterprises (FFE) is an interest and service organisation for small and medium-sized enterprises (SMEs) for all fields around entire Finland and their owners. As Finlands largest organisation, representing over 100.000 enterprises, we work every day to support free entrepreneurship and an entrepreneur-friendly society.

Danish Shipping is generally positive about the purpose of ensuring a high and unform level of customer protection among Member States of the Union. Danish Shipping believes that the passenger rights regulation (Regulation 1177/2010 on the rights of passenger when travelling by sea and inland waterway) containing provision for a minimum of passenger rights at sea, is functioning well in its current form.

According to article 17, 18 and 19, a security must be provided for the refund of all payments made by or on behalf of travellers in the case of an insolvency. During the bankruptcy of Thomas Cook, many hotels suffered serious damage due to the organizer's insolvency. The directive should be amended in order to provide a form of protection for small and medium-sized enterprises too.

Crisis case Corona The Package Travel Directive (PTD), as valuable as a consumer protection instrument, is not designed to adequately address a global disaster like a pandemic. The complete and persistent collapse of the world’s travel market is an unprecedented situation. Suppliers had no possibility of compensating for outages in one region by travelling to another region.

Filed in German · English published by the European Commission

The Package Travel Directive (“PTD”) has now been applied since 2018 and these last three years have allowed for a “stress test” of its provisions in light of its objectives: the proper functioning of the internal market and a high level of consumer protection in the area of package travel.

Favourite option: option 3 Revision of the framework The pandemic has shown the need for a harmonised reform of both PTD and passenger rights regulations (in particular air travel). It is not possible to obtain a directive that is clear, future proof and guaranteeing a level playing field by only revising the PTD.

Opinion of the Bundesverband Deutscher Omnibusunternehmen e.V. (bdo) on the combined assessment timetable for the revision of the Package Travel Directive. The Bundesverband Deutscher Omnibusunternehmen e.V. (bdo) is pleased to submit an evaluation of the Package Travel Directive for examination.

Filed in German · English published by the European Commission

In annex you'll find the feedback from VVR and UPAV In general, the following objectives should be pursued: - Administrative simplification - Force majeure must be properly defined and accepted and the organizer’s responsibility limited in this respect - Reimbursement period must be aligned for the whole tourist chain, if not adjusted - Level playing field must be realized and insolvency insurance must be thoroughly…

FITE contribution to the European Commission report on the PTD application September 2021 The FITE gathers more than 25 National Equestrian Tourism Organisations (NETOs) within the European Union but also outside Europe: in Canada, China, Morocco… Some of the NETOs are national sport federations such as Germany, Spain or France.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

FFE contribution to the European Commission report on the PTD application September 2021 The French Equestrian Federation (FFE) is the French sport federation for equestrian sports with 9500 equestrian holdings and more than 660 000 licence holders. It represents 35 000 direct jobs, making horse riding the largest private employer for sport in France.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Directive on package travel and linked travel arrangements (PTD) is an important consumer protection instrument as it includes rules on consumer protection in case of insolvency of a tour operator and key consumer rights in case of cancellation for unavoidable and extraordinary circumstances as well as clear liability rules.

Statement of the Verband Internet Reisevertrieb e.V. (VIR) on the combined evaluation roadmap for the revision of the Package Travel Directive We are pleased to submit our fact- and experience-based assessment of the Package Travel Directive 2302/2015 to the consideration of the DG JUST. Please find our statement attached.

POLICY PAPER Ref. Ares(2021)5693238 - 17/09/2021 SMEunited input to the EC Roadmap on the Revision of the Package Travel Directive (PTD) SMEunited welcomes the opportunity to comment on the European Commission’s Roadmap on the Revision of the Directive (EU) 2015/2302 on package travel and linked travel arrangements, published on 6 August 2021. SMEunited agrees with the objectives of the initiative.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

DECO considers that the current Directive needs to be reviewed in view of addressing several shortcomings, and that the evaluation including a thorough assessment of whether the original objectives of the Directive are still fit for purpose as when the Directive was first proposed is absolutely key and should really be the starting point.

The SPANISH CONFEDERATION OF THE EUROPEAN COMMITTEE ON THE COMMITTEE OF THE COMMITTEE ON THE COMMITTEE FOR COMBINED EVALUATION AND INITIAL IMPACT REPORT ON THE DIRECTIVE (EU 2015/2302) OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL ON COMBINED WITH AND INVITED IMPACT REPORT (EU)

Filed in Spanish · English published by the European Commission

Response to Commission’s Roadmap/Impact Assessment on the Packaged Travel Directive The travel industry represents a clear example of how the pandemic has radically altered the landscape and expectations of all stakeholders of the ecosystem, such as travel agencies, airlines and, of course, consumers.

The European Holiday Home Association (EHHA) which is a united voice for short-term rentals, supports the Commission’s further work on the application of the Directive 2015/2302 on package travel and linked travel arrangements (“Package Travel Directive”) and provides its comments to the Commission’s further work on PTD(attached).

vzbv welcomes the Commission's approach that the aim must be to strengthen consumer protection - not to reduce it. Consumers need special protection, especially in times of crisis. The following is a list of aspects that we believe are particularly urgent for evaluation and improvement (selection): 1.

The FIA European Bureau welcomes the review of the PTD, with a view to increase the level of consumer protection, especially under extraordinary circumstances. These are the aspects that, in our opinion, deserve being reviewed: Raising awareness of travelers’ rights The 2020 Eurobarometer showed that only 32% of respondents are aware of passenger rights in the EU.

The Austrian Federal Chamber of Labour wishes to sumbit feedback within this initaitive with a position/policy-paper we just recently published on our website https://akeuropa.eu/policy-brief-european-travel-law-addressing-current-issues-and-challenges-light-covid-19, that directly addresses the issues and questions of this initative. Thank you for your consideration!

Consumer protection is of utmost importance. However, in the current package travel law, there is a significant imbalance between consumer protection and the counterpart liability of the tour operator. The Corona crisis has proved that this is an unsustainable situation and that the law must therefore be amended as a matter of urgency.

Filed in Dutch · English published by the European Commission

Currently representing over 21 million members, ADAC is the largest automobile club in Eu-rope and the second-largest in the world. As a recognized consumer protection organisation, ADAC focuses on road traffic, consumer rights, road safety and road safety education. The ADAC welcomes the review of the PTD with a view to increase the level of consumer protection, especially under extraordinary circumstances.

An overhaul of the Package Travel Directive is required because of the blurred lines between the Package Travel Directive and the difficulty in implementing and enforcing the rules of the Linked Travel Arrangements which were supposed to reflect the onset of digital markets. The industry is being overhauled by digitalisation and the legislation must reflect these changes.

I would like to make two comments. Firstly, we find limitations on combining long-distance bus tickets with buses from Cercanias/suburban/urban areas managed by consortia and public metropolitan areas. We believe that it should be possible to facilitate the digital sale of these tickets in order to make the combination easier and ultimately easier for the passenger to book the through-ticket.

Filed in Spanish · English published by the European Commission

The Covid crisis has revealed a number of loopholes and “loopholes” left out of the Directive: Indeed, it has been extremely difficult to apply the concept of extraordinary circumstances (in particular for cancellation at no cost due to the traveller) to a changing situation in time and space, where the Directive provides for conditions for “fixed” situations (e.g.: Attack).

Filed in French · English published by the European Commission

As a niche touroperator I would like to share my opinion about some aspects of the existing travelpackage law. The covid-crisis showed that this law really goes beyond every common sense. In the existing laws all responsabilities and liabilities are with the touroperator.

Thank you for providing the possibility to give feedback! Please find it more: — The information requirements under Article 5 of the PR Directive and the definitions in Article 3 of the Directive should be made clearer/less ambiguous. It must be clear to the consumer, the customer, who is the organiser/contractor. Some organisers refer to themselves as ‘agencies’ and send out travellers in the circle.

Filed in German · English published by the European Commission