Open Letter

Open Letter to Commissioner Reynders: Protecting Consumers and Ensuring Availability of Travel Packages

Today, in an open letter to Commissioner for Justice, Didier Reynders, co-signed by ECTAA, we voiced our deep concerns regarding the European Commission’s plans to impose a limitation of pre-payments on package organisers in the revised Package Travel Directive (PTD). Ahead of the official release of the legislative proposal later this year, we urge policymakers to ensure that any changes to the PTD provide consumer protection while safeguarding the future of travel packages.

As a part of its evaluation of the PTD, the European Commission is giving serious consideration to a provision to restrict consumers pre-payments to package travel organisers to 20% of the overall package price. While the intention is to protect consumers, this measure risks placing an unsustainable financial burden on organisers. Airlines, for example, require full upfront payment for the flight component, which often exceeds the proposed 20% threshold.

A related option under consideration is to allow organisers the flexibility to ask for pre-payments above 20% if they are required themselves to pre-pay suppliers. This approach would be a completely empty protection for consumers as it fails to account for the substantial pre-payments typically required by travel service providers, which generally reach up to 80% of the total package value.

We acknowledge the European Commission’s concerns regarding reimbursement delays experienced during the pandemic. However, a more effective approach is needed to enhance consumer protection, without disproportionately burdening travel agents and endangering the viability of travel packages. Delivering an ambitious reform of the EU passenger rights framework and introducing a mandatory insolvency protection scheme for the airlines will be essential in this regard.

“We firmly believe that consumer rights should be safeguarded while preserving the availability of well-protected travel packages,” stated Emmanuel Mounier, Secretary General at eu travel tech. “Regulating packages out of existence would undermine the policy goals of the Package Travel Directive and negatively impact consumer choice and affordability.”