19 April 2022: The European Commission (DG JUST) launched last February a public consultation on Package Travel and Linked Travel Arrangements (LTAs) to seek opinions from stakeholders on their experiences regarding the application of the EU current rules as well as on the impacts of options for potential changes. Feedback is open until 10 May 2022.

ERA believes that the current rules on cancellation, liquidity and reimbursements for package travel are not sufficiently clear and should be amended to provide: 
• better clarity in the relation between “official travel warnings” and extraordinary circumstances as well as an alignment with the EU261 rules;
• further information: traders should be obliged to inform travellers clearly which trader is acting as an organiser, retailer or service provider in connection with a package and about their obligations towards travellers;
• a 14-day refund period where package travel contracts are terminated because of unavoidable and extraordinary circumstances.

Regarding insolvency, the existing insolvency protection is sufficient since an extension of the protection would imply excessive costs. Therefore, the Commission should enforce the rules better in relation to the Member States:
• ERA proposes a coordinated EU approach to national insolvency protection schemes and a level playing field;
• no establishment of a crisis fund.

On “Linked Travel Arrangements (LTAs)”:
• with regards to the rules as defined in Article 3(5)(a), i.e. the purchase of two services at one point of sale, ERA suggests the Commission to adopt a definition or official guidance on the criterion ‘single visit or contact’ to better distinguish LTAs from mere stand-alone services;
• with regards to the rules on LTAs as defined in Article 3(5)(b), i.e. the purchase of an additional travel service at a different point of sale where a contract is concluded no later than 24 hours after the confirmation of the booking of the first travel service, ERA proposes that this second type of LTA should be abandoned without any substitute rules due to its complexity in identifying the rights and responsibilities of each of the parties.
 

23 February 2022: The Commission launched a public consultation on package travel and linked travel arrangements (LTAs) on 15 February 2022 to seek opinions from stakeholders on their experiences and perceptions regarding the application of the EU current rules as well as on the impacts of options for potential changes. The initiative is led by DG JUST (Justice and Consumers) and the questionnaire is open for feedback is open until 10 May 2022.

The questions in the generic part of the questionnaire concern the following topics:

• market developments;
• definitions and scope of application;
• cancellations, liquidity and reimbursements;
• insolvency protection, pre-payments and preparation for a liquidity crisis;
• Linked Travel Arrangements (LTAs); and
• other questions (environment, insurances etc.)

The reply options offered in the questionnaire take into account feedback from stakeholders already received as well as recommendations from relevant studies and reports, including the European Court of Auditors’ report on air passenger rights during the COVID-19 pandemic published in June 2021.

See the survey at: https://ec.europa.eu/eusurvey/runner/reviewpackagetraveldirective?surveylanguage=en [1]