Passenger rights in the context of multimodal journeys

The Swedish Aviation Industry Group hereby submit comments on the European Commissions respective proposals on the enforcement of passenger rights and multimodal passenger rights. Please see attachment. Yours truly, [name removed] Director Industry Affairs Swedish Aviation Industry Group

A4E welcomes the opportunity to provide feedback on the European Commissions respective proposals on the enforcement of passenger rights and multimodal passenger rights. Our preliminary views are set out in the attachment and will be detailed further in our position papers which will be published soon.

ALLRAIL, the Alliance of Passenger Rail New Entrants, is a non-profit association representing independent passenger rail companies (e.g. rail operators, ticket vendors, and rolling stock lessors) in Europe. ALLRAIL advocates for faster market opening in passenger rail in order to accelerate modal shift to rail and achieve the ambitious climate change reduction goals of the EU Green Deal in the transport sector.

This response represents easyJet Group's views. easyJet Group is comprised of easyJet holidays and easyJet airline. easyJet airline is one of Europes largest airlines with bases across Europe and operating flights on a wide network of city and beach holiday routes across Europe and North Africa.

This response represents easyJet Groups views. easyJet Group is comprised of easyJet holidays and easyJet airline. easyJet airline is one of Europes largest airlines with bases across Europe and operating flights on a wide network of city and beach holiday routes across Europe and North Africa. easyJet airline sells packages specifically flights plus car rental.

Passenger rights are a major achievement of the EU, as they create common and harmonised rules guaranteeing strong rights for travellers. However, travel markets have evolved with the arrival of new actors such as online booking intermediaries. Recent times have highlighted shortcomings of current Passenger Rights Regulations, most notably lax enforcement.

In the opinion of the Pro Railway Foundation, the idea, aims and objectives described in the draft regulation of the European Parliament and of the Council on passenger rights in the context of multimodal travel are correct and will contribute to improving the standard and observance of passenger rights in multimodal transport.

The ONCE Foundation welcomes the Commission’s new proposal to revise the European regulation on passenger rights in the context of multimodal journeys. As part of our mission to defend the rights of persons with disabilities and their inclusion in all aspects of society, the ONCE Foundation calls for regulatory frameworks to be drawn up to guarantee the rights of persons with disabilities in all areas, including…

Filed in Spanish · English published by the European Commission

Ladies and gentlemen, the Verbraucherzentrale Bundesverband e.V., welcomes the fact that the European Commission has put forward a proposal for a regulation to improve the enforcement of passengers’ rights and offers an opportunity to comment on it in the context of a public consultation. The detailed assessment of the proposal for a Regulation can be found in the attached document. Yours sincerely, [name removed]

Filed in German · English published by the European Commission

Dear Sir, the proposed revision of Regulation 181/2011 on risk-based monitoring of passenger rights does not take into account the principles under which risk assessment should be carried out, including which aspects will be analysed (Article 4 – Amendments to Regulation (EU) No 181/2011). In Article 28a.

Filed in Polish · English published by the European Commission

The Austrian Association of Public Economics and Public Industries (VÖWG) attaches the opinion on the Proposal for a Regulation of the European Parliament and of the Council amending Regulations (EC) No 261/2004, (EC) No 1107/2006, (EU) No 1177/2010, (EU) No 181/2011 and (EU) 2021/782 as regards the enforcement of passenger rights in the Union and on the proposal for a Regulation of the European Parliament and of…

Filed in German · English published by the European Commission

ADAC e.V. is a non-economic association which considers its primary task to promote and maintain the mobility of its members. Assistance, advice and protection after breakdown, accident and disease describe the core of the activities. The ADAC has shown a strong commitment to road safety and education.

Filed in German · English published by the European Commission

ADAC e.V. is a non-economic association which considers its primary task to promote and maintain the mobility of its members. Assistance, advice and protection after breakdown, accident and disease describe the core of the activities. The ADAC has shown a strong commitment to road safety and education.

Filed in German · English published by the European Commission

Dear Sir or Madam, Please find attached a joint contribution from FIM and Pearle* on behalf of the European live performance sector, which needs an improved legal framework for transporting musical instruments by air or rail. Indeed, mobility within the EU is paramount for professional musicians, and inadequate restrictions may lead those carrying big musical instruments to impossible situations.

ECTAA appreciates the possibility to provide feedback to the COM proposal for a Regulation amending Regulations (EC) No 261/2004, (EC) No 1107/2006, (EU) No 1177/2010, (EU) nNo 181/2011 and (EU) 2021/782 as regards enforcement of passenger rights in the Union. Attached is our detailed position.

Airlines International Representation in Europe welcomes the proposal for a Regulation of the European Parliament and of the Council amending Regulations (EC) No 261/2004, (EC) No 1107/2006, (EU) No 1177/2010, (EU) No 181/2011 and (EU) 2021/782 as regards enforcement of passenger rights in the Union. Please find enclosed a detailed paper with our main comments, and remarks.

Airlines International Representation in Europe (AIRE) truly welcomes the invitation of the European Commission to provide feedback on the Proposal for a Regulation on Passenger Rights in the context of multimodal journeys. Please find enclosed a detailed summary of our comments and remarks.

The Consumer Ombudsman of the Finnish Competition and Consumer Authority (FCCA) is the national enforcement body of all the transport modes (air, waterborne, rail, bus and coach) in Finland with the primary duty to ensure that the marketing, contract terms and commercial practices of carriers are in line with the passenger rights Regulations for the collective benefit of consumers.

The Consumer Ombudsman of the Finnish Competition and Consumer Authority (FCCA) is the national enforcement body of all transport modes (air, waterborne, rail, bus and coach) in Finland with the primary duty to ensure that the marketing, contract terms and commercial practices of carriers are in line with the passenger rights Regulations for the collective benefit of consumers.

RATP Group welcomes any EC initiative aiming at improving passenger rights, and notably accessibility for persons with disabilities or reduced mobility during multimodal journeys, of which all the transport services concerned fall under the scope of the EU legislation on passenger rights.

The Swedish Association of Local Authorities and Regions considers that the Regulation should not apply to journeys by local and regional public transport, but only to long-distance journeys. For local and regional public transport, adequate passenger rights are generally available in the Member States.

Filed in Swedish · English published by the European Commission

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.

The Fédération Internationale de lAutomobile European Bureau (FIA EB) strongly supports the European Commission proposals for a revised Package Travel Directive and passenger rights regulations. Travellers will benefit from improved rights and strengthened consumer protection. Detailed feedback can be found in attached file.

Dear Sir, Madam, Please find attached the opinion of the Federal Chamber of Labour (BAK) on the Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulations (EC) No 261/2004, (EC) No 1107/2006, (EU) No 1177/2010, (EU) No 181/2011 and (EU) 2021/782 as regards the enforcement of passenger rights in the Union (COM(2023) 753 final). Yours sincerely,

Filed in German · English published by the European Commission

Continuous improvement of travellers’ experience is a priority for the SNCF group, even beyond legal obligations. The Commission’s proposal for a regulation is therefore a priority issue. However, it comes in a context of a nascent market and must not prevent the emergence of new multimodal offers by creating an inadequate framework.

Filed in French · English published by the European Commission

Please find attached the opinion of the Passenger Rights Agency (Apf) on the proposal for a Regulation amending Regulations (EC) No 261/2004, (EC) No 1107/2006, (EU) No 1177/2010, (EU) No 181/2011 and (EU) 2021/782 as regards the enforcement of passenger rights in the Union (COM(2023) 753). Yours sincerely, [name removed]

Filed in German · English published by the European Commission

Summary of our opinion (the detailed opinion can be found in the annex) The ÖAMTC has long stressed the importance of passengers enjoying the same high level of protection when switching between modes of transport during a journey as passengers travelling by air, rail, bus, sea and inland waterway.

Filed in German · English published by the European Commission

The Austrian Automobile, Motorcycle and Touring Club (ÖAMTC) is Austria’s largest mobility club and represents the interests of more than 2.5 million members. The ÖAMTC is responsible for protecting the rights of consumers, drivers, other mobile people and travellers.

Filed in German · English published by the European Commission

Dear Sir/Madam, please find attached the opinion of the Passenger Rights Agency (Apf) on the proposal for a Regulation on passenger rights in the context of multimodal travel (COM(2023) 752). Yours sincerely, Norman Schadler

Filed in German · English published by the European Commission

The attached paper contains European Regions Airline Association views on the Passenger Mobility Package and in particular the proposals related to air passenger rights i.e., amending Regulation (COM(2023) 753) and passenger rights in the context of multimodal journeys (COM(2023) 752).

Pearle*-Live Performance Europe supports the Commissions initiative to increase the protection of passengers. In the cultural sector performers travel a lot, as it is an inherent part of their professional activity. In this regard, in a capacity of passenger, they will equally benefit from the proposed package on passenger rights.

The network of European Consumer Centres (ECC-Net) welcomes the opportunity to provide comments on the European Commissions initiative with regards to a better protection for passengers and their rights. ECC-Net therefore encloses its paper on the Passenger Mobility Package and is available to answer further questions. Kind Regards [name removed] Policy Paper Group (ECC-Net) Head of European Consumer Centre Austria

The European Network of Business Travel associations (BT4Europe) appreciates the opportunity to give feedback on the revision of existing regulation on Passenger Rights in Europe. The proposal is definitely a step in the good direction, but there are a few details we believe must be amended; 1.

The attached paper contains EPF's response to the Passenger Mobility Package, focusing on the Passenger Rights proposals. Multimodal passenger rights: welcome as a first step in the right direction, but better protection needed for combined multimodal tickets. Enforcement: some improvements, but no game-changing new provisions.

Dear Sir / Madam, Please find attached the European Disability Forum's analysis of the enforcement of passenger rights. EDF welcomes the proposal on enforcement of passenger rights and, in particular, supports the following points: The amendment to Article 2 of Regulation 1107/2006 to ensure that, whenever a person with a disability is required to travel accompanied, the air carrier, agent or tour operator pay the…

Dear Sir / Madam, Please find attached the European Disability Forum's analysis of the proposed regulation on passenger rights in the multimodal context. EDF welcomes the proposal on passenger rights and, in particular, supports the following points: The provisions of accessible information in Articles 3, 8, 13, 18 and 10 subject to a clearer reference to the European Accessibility Act The provision of assistance…

The IRU Position Paper on Passenger Mobility is attached to this consultation. IRU welcomes the efforts of the European Commission to improve the travel experience of passengers by strengthening their rights across all modes of transport, including multimodal journeys and tourism packages.

Interferry is a shipping association representing the ferry industry world-wide. ECSA represents 21 national shipowners associations based in the EU and Norway. In November 2023, the European Commission presented a series of proposals designed to improve the experience of passengers and travellers by strengthening their rights.

Ladies and gentlemen, the Verbraucherzentrale Bundesverband e.V., welcomes the fact that the European Commission has put forward a proposal for a regulation to improve the rights of multimodal travellers and offers an opportunity to comment on it through a public consultation. The detailed assessment of the proposal for a Regulation can be found in the attached document. Yours sincerely, [name removed]

Filed in German · English published by the European Commission

CONFEBUS took note of the proposal on passenger rights in the context of multimodal journeys, adopted by the European Commission on 29 November 2023. The proposal aims to address passenger rights specifically in situations involving multiple modes of transport. This new proposal allocates obligations based on their multimodal ticketing types, covering carriers, intermediaries and station/terminal managers.

Filed in Spanish · English published by the European Commission

CONFEBUS took note of the proposal for a revision of the Passenger Rights Regulation. This proposed legislative amendment affects the rights of passengers in bus and coach transport within the EU, which are mainly governed by Regulation (EU) No 181/2011, which covers regular and certain non-scheduled services with a scheduled service duration of 250 km or more.

Filed in Spanish · English published by the European Commission

We have uploaded our position paper on the Regulation on passenger rights in the context of multimodal journeys and Review of the passenger rights Regulations. For a short overview, our main messages are: Responsibilities and duties of each entity need to be better defined and balanced. Proposal introduces many new obligations for carriers, while being unreasonably light on the responsibility of the intermediaries.

Travel improving passenger protection and DL rights: 13 March 2024 link: Travel to improve the protection of passengers and their rights (europa.eu) “Fair mobility also requires the protection of passengers and their rights”, as highlighted in the European Commission’s Sustainable and Smart Mobility Strategy.

Filed in French · English published by the European Commission

Dear Sirs, On behalf of the Network of European Consumer Centres and in my position as rapporteur of the Policy Paper Focus Group we hereby send ECC-Net's paper on the passenger mobility package. Please do not hesitate to contact us if you have any questions. Best regards, [name removed], Rapporteur Policy Paper Focus Group/ECC-Net, https://www.eccnet.eu/, [email removed]

The Global Business Travel Association (GBTA) welcomes the presentation by the European Commission of a revised framework for passenger rights in Europe. The proposals represent an ambitious strengthening of existing legislation and address the key issues that business travellers face in terms of reimbursement, provision of information, and standardisation.

Danish Shipping is generally positive about the purpose of ensuring a high and unform level of customer protection among Member States of the Union. The proposal addresses passenger rights in multimodal transport, where multiple modes of transportation are used during one single journey such as a combination of bus, ship, airplane, and railway.

I am President of the JK5022 Flight Affects Association (Madrid-20.8.2008-154 deceased and 18 survivors) and also of the International Federation of Victims of Air Accidents and their Families, recognised by ICAO in 2016, whose official seat is in Madrid-Spain.

Filed in Spanish · English published by the European Commission

A4E welcomes the opportunity to provide comments on the European Commission’s initiative to review the passenger rights regulatory framework. A4E would like to stress that the pending reform of Regulation 261/2004 remains critical for European airlines and consumers and would make a substantial contribution to addressing the issues mentioned in the call for evidence.

The Europe On Rail initiative (www.europeonrail.eu), an European Civil society initiative to promote cross-borders passengers rail, represented here by the association ECO-UNION: 1- Acknowledge the Commission has rightly recognized the shortcomings of the current passenger rights implementation. 2- Regret that the scope of the initiative does not allow to fully tackle the issues with rail passenger rights.

This initiative addresses passenger rights in the event of delays and cancellations, as well as protection in the event of insolvency. A very significant obstacle to the use of rail when travelling to airports is the cancellation of transport entitlements in the event of a delay by rail or (on the return journey) of the aircraft.

Filed in German · English published by the European Commission

Public transport is an integral part of environmentally friendly mobility. Therefore, Pro Bahn calls for the following minimum standards for passenger rights: •Continuous mobility opportunities to all localities every day.

Filed in German · English published by the European Commission

Consider whether its nearly 5 million members in the Netherlands, touring club ANWB where to give you some suggestion on the call for evidence for the impact assessment on the better protection for passengers and their rights initiative.

Filed in Dutch · English published by the European Commission

The European Passengers’ Federation, representing 39 organisations from 21 countries, welcomes the EC’s initiative to review the passenger rights regulatory framework. In EPF’s perspective, the initiative needs to address a number of important issues: how to better protect passengers in a multimodal context; harmonizing and enforcing existing rules; extending current protection taking into account lessons learned…

The European legislative framework already covers all modes of transport (air, rail, boat and bus) by means of the various regulations in force. Provision is made for a set of passenger rights and obligations for carriers which, while aiming at the protection of passengers, falls short of the desired level of protection, affecting consumer confidence in the transport sector.

Filed in Portuguese · English published by the European Commission

UITP shares the Commission's ambition for better protection for passengers and their rights, especially in a multimodal perspective. Passengers are at the centre of public transport operations. The public transport sector therefore shares the following contribution to this initiative aiming at improving the passenger rights regulatory framework, addressing lessons from the COVID-19 pandemic.

WIZZ AIR’S RESPONSE TO THE EUROPEAN COMMISSION’S CONSULTATION ON PASSENGER RIGHTS I. TRAVEL AGENCIES AND OTHER INTERMEDIARIES The absence of EU-wide rules regulating online travel agencies is commonly recognized as a severe issue by all carriers and passengers, and therefore Wizz Air considers this as a priority topic where guidance and stricter approach of the European Commission is required.

GBTA welcomes the opportunity to contribute to the European Commission’s call for evidence through its feedback consultation on better protection of air passenger rights. This initiative is particularly timely as COVID-19 has impacted business travel over the last two years and rendered obsolete the Commission’s 2013 proposal.

BEUC welcomes the opportunity to comment on the call for evidence for an impact assessment on the better protection for passengers and their rights initiative. In attachment you will find the preliminary points that BEUC considers crucial to consider in the event of a review of passengers rights regulations, to ensure a high level of consumer protection (particularly in times of crisis), to restore consumer…

As a recognised consumer association with more than 21 million members, the German Automobilclub ADAC e.V. with great interest in the development of aviation legislation. Operations in Germany are not running smoothly.

Filed in German · English published by the European Commission

1. Ensure consumer protection: The harmonisation of the various EU rules on passenger rights and obligations is welcome in principle. A patchwork of different rules, sometimes contradictory, does not create confidence among travellers and makes travel more complicated.

Filed in German · English published by the European Commission

>>Challenges: GISAD welcomes the initiative better protection for passengers. However, it is unlikely that only a legal framework can achieve the challenges in terms of optimal flexibility of travel and integration of all private and public mobility providers. GISAD has already commented on modular mobility http://gisad.eu/en-eu-initiative-multimodal-digital-mobility-services/ .

Interferry would like to share the following views: Aim 1) We support efforts to improve clarity of the Maritime Regulation (the MarReg). The MarReg has not been tested in the CJEU to the same extent as the Aviation Regulation and principles remain unclear. Aim 2) Improved awareness and clarity will assist passengers to claim and understand what they are entitled to and not entitled to.

eu travel tech welcomes the opportunity to comment on the European Commission’s call for evidence for an Impact Assessment regarding the the initiative on Better protection for passengers and their rights. See attached eu travel tech's position paper.

CER’s members considers the protection of their customers first and foremost as the sector’s own long-standing commitment. CER members understand that the passenger experience is the decisive factor when customers choose their transport mode.

Ecosystem approach is still not applied to passenger protection and should be extended to the legislative regime of isolated instruments (passenger rights regulations, PTD, air services regulation, platform rules) whose gaps and inter-relations need ambitious reconsideration.

The impact of the COVID-19 crisis on the tourism industry and the post-COVID-19 scenario presents significant challenges for restoring consumers’ confidence. The international fragmentation of tourism consumer rights may represent an additional deterrent to international tourism recovery.

European aviation has a long-held tradition of defending passenger rights. Indeed, based on the experience acquired in the past, those rights have been recognised and transposed to other modes of transport. European airports are committed to the continuous improvement of the quality of the services offered to passengers and to the effective enforcement of their rights.

Combined views of Stena Line Irish Ferries Brittany Ferries Aim 1) We support efforts to improve clarity of the Maritime Regulation (the MarReg). The MarReg has not been tested in the CJEU to the same extent as the Aviation Regulation & principles remain unclear. Aim 2) Improved awareness & clarity will assist passengers to claim & understand what they are entitled to & not entitled to.

No need for legislation on airline bankruptcy: Existing mechanisms to mitigate the risks associated with airline bankruptcy are effective: There are mechanisms, protections and voluntary agreements in place today that adequately cover the repatriation of passengers when airlines become insolvent without the need for legislation.

ERA welcomes the opportunity to comment on the European Commission’s call for evidence on the Review of the Passengers rights regulation and wishes to make a substantial contribution to the ongoing debate. Over the last 30 years, the air travel single market has been a great achievement of the European Union: successive regulatory packages have made it possible for any European airline to operate anywhere in Europe…

Thank you for this important initiative! The Covid19 pandemic in particular, with associated cancellations, cancellations, rebookings and also insolvencies in the sector, show the need for optimised rules and clarifications. Insolvency protection for customers in the event of an airline bankruptcy is urgently needed! In the event of insolvency of the organiser or service provider, e.g.

Filed in German · English published by the European Commission

Combined views of Brittany Ferries Irish Ferries Stena Line Aim 1) We support efforts to improve clarity of the Maritime Regulation (the MarReg). The MarReg has not been tested in the CJEU to the same extent as the Aviation Regulation and principles remain unclear. Aim 2) Improved awareness and clarity will assist passengers to claim and understand what they are entitled to and not entitled to.

The contract of passage by sea and inland waterways has a very different characteristic from the rest of maritime contracts and this is that, although it is obvious, people are transported, people who in turn have mostly the status of consumers.

In a transversal way, for all four regulations by mode, FNAUT considers that it is judicious to work on improving the protection of passengers and their rights, in particular from the angle of : - Taking into account the situation of people who can no longer travel for climatic, health or geopolitical reasons, etc., even though the means of transport they have planned is not cancelled by the company.

CONFEBUS, the Spanish Confederation of Bus and Coach Transport, takes note of the announcement by the European Commission to carry out an initiative to review the regulatory framework of passenger rights in all modes of transport, in particular to ensure its resilience against extensive travel interruptions, and to include options for multimodal tickets.

Horizontally, for all four regulations by mode, FNAUT considers it appropriate to work to improve the protection of passengers and their rights, in particular from the point of view of: — Take into account the situation of persons who are no longer able to travel for climatic, health, geopolitical reasons, etc., even though the means of transport they have planned are not cancelled by the undertaking.

Filed in French · English published by the European Commission

ECTAA welcomes the call for evidence for an impact assessment on passenger rights. We are happy to see that reference is made to the Sustainable and Smart Mobility Strategy as well as the report of the European Court of Auditors report on the application of air passenger rights during the pandemic. - B2B refund issues resulting from a lack of regulation thereof.

The European Community Shipowners' Associations (ECSA) believes that the current Regulation (EU) No 1177/2010 concerning the rights of passengers when travelling by sea is fit for purpose and sees no compelling need for any new initiative. In fact, ferry and cruise sectors are known for their high standards of customer service.

In order to encourage non-community-based tourism, the first step is to facilitate all aspects of travel in general by air, private car or train. The management of travel by private car or train is not a problem and there are several alternatives and, in the case of a train, it is easy to manage the ticket, as well as cool journeys depending on the length of the journey.

Filed in Portuguese · English published by the European Commission

The European Disability Forum (EDF) welcomes the European Commission’s initiative to gather evidence for the purpose of assessing the impact of the EU passenger rights regulatory framework, particularly related to Regulations on air passenger rights for passengers with reduced mobility (PRM), waterborne and bus & coach passenger rights.

IRU considers that the current provisions under Regulation (EU) No 181/2011 concerning the rights of passengers in bus and coach transport are proportionate and sufficient to ensure that the rights of passengers are protected.

The main challenge regarding air passenger rights, and how to better protect them, is to be able to predict most situations that passengers may find themselves in. Crisis like the current Covid-19 pandemic, its duration and consequences are hard to foresee. So far, passengers have been most affected by the lack of an appropriate reimbursement infrastructure and the lack of rerouting options.

EPTO supports the concept of fair and reasonable rights for public transport passengers. In formulating any changes to the existing passenger rights for travellers by rail and by bus and coach, the Commission must remain mindful of the potential impact of any measures that provide for additional compensation or replacement services for passengers.

The Austrian Chamber of Labour (AK) would like to give the following feedback to the EU Commission´s initiative "Travel - a better protection for passengers and their rights on EU-level": It is well known that the coronavirus pandemic has hit consumers and companies hard, particularly in the field of travel.

Obstacles in buses The following compilation of bus travel problems from the perspective of blind and visually impaired people does not claim to be exhaustive and is the result of the consultation of European experts who themselves have visual impairments.

Filed in French · English published by the European Commission

An issue has been seen with regards to OTA's - when an OTA of questionable business practices sells tickets to flights, however upon flight cancellation, even if the airline refunded the ticket to the original payer (the OTA), the OTA itself does nothing to forward said refund to the affected passenger.

I would like to bring up the issues related to the rights of passengers traveling on virtually-interlined flights, which are currently very popular in the European air travel marketplace. Vendors of virtually-interlined flights combine unrelated flights (e.g. Wizz Air + Ryan Air) into a seamless reservation sold as one air ticket.

I’d like to bring a report by SEO Economics on insolvency protection in aviation to the attention of the Commission. The report was commissioned by the Dutch ministry for Infrastructure and Water Management and published in 2021. It is an impact assessment of a national ticket guarantee fund. The report assess the impact a Dutch guarantee fund would have on consumers, the aviation industry and public authorities.