Industry Position on Commission’s Recommendations on Intra-EU and International Travel

70 travel and tourism organisations express their support to any effort – based on scientific evidence – to keep protecting and ensuring the freedom of movement and avoid a patchwork of diverging national measures within the EU/EEA as well as internationally.

In light of the evolving epidemiological situation and the continued emergence of new COVID-19 variants (e.g. Omicron), the European Tourism Manifesto alliance, a group of 70 public and private travel and tourism organisations and the voice of the sector in Europe, acknowledges the European Commission’s proposals for updated Council Recommendations for intra-EU travel1 and for inbound travel to the EU2 published last week.

We welcome the European Commission’s continued efforts to ensure a coordinated approach to travel measures and support the proposed shift to an individual traveller-based approach, in which a valid EU Digital COVID Certificate (DCC) is sufficient to travel without additional requirements (no further testing or quarantine). This is in line with the most recent European Centre for Disease Prevention and Control (ECDC) authoritative and science-based analysis3, which confirms that travel restrictions generally have no effective impact on the spread of the virus in Europe.

The implementation of the EU DCC has been a huge success and it is becoming an international standard. In this context, we would like to emphasise the following points:


  • EU Digital COVID Certificate (DCC) validity: It is of the utmost importance that all EU Member States agree on a standard duration of the vaccination certificate, to avoid fragmentation of national legislation and discrepancies between Member States. However, the recommendation to shorten vaccine certificate validity to nine months and require an additional (“booster”) dose to maintain this status will create asymmetry between EU countries with different national vaccination levels as well as booster availability.
  • Swift implementation: We urge Member States to agree on the updated Council Recommendations considering our suggestions outlined in this paper as soon as possible to ensure their uniform implementation before the festive period. The implementation date of 10th January 2022 proposed by the European Commission would be too late to positively impact the Christmas holidays – both citizens and industry require certainty and coherent rules to prepare for end-of-year travel. NB: A fragmented approach will also have an impact on 2022 spring and summer seasons, as travellers (both EU and non-EU citizens) start planning their holidays around Christmas.
  • EU Digital Passenger Locator Form (dPLF): We call on Member States to swiftly adopt the existing dPLF to achieve further harmonisation of travel measures and facilitate contact tracing across EU borders.
  • ECDC map: We are surprised that the ECDC regional colour-coded map will continue to be used as a source of information as it relates to travel restrictions, despite the European Commission’s individual traveller-based approach. Even with the new vaccination criteria (added to incidence and testing rates), we believe this will generate further confusion for intra-EU travel, in particular for families with children due to diverging measures.
  • Travel from outside the EU based on WHO-approved vaccines or recovery: We welcome the proposal for all Member States to recognise World Health Organization (WHO)-approved vaccines. However, the additional requirement of providing a negative PCR test for travellers vaccinated with a WHO-approved, but not EMA-approved vaccine, could create a two-tier system that would become very cumbersome to put in place. We therefore call on Member States to recognise the whole list of WHO-approved vaccines without additional requirements for travellers. This point equally goes for recovered travellers; there is no justifiable reason why an additional PCR test is required from recovered non-EU travellers while this is not required from EU travellers.


The European Tourism Manifesto alliance gathers 70 European public and private organisations, covering the whole tourism value chain and beyond. The alliance calls on the European Union for action on key policy priorities for the tourism sector. For more information, please visit The full list of supporting organisations can be found at