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Project for the European Parliament's IMCO committeeStudy on the performance of the Package Travel Directive

Project period:
April – September 2023

Client:
European Parliament – Committee on the Internal Market and Consumer Protection (IMCO)

Project partner:
VVA

Travel packages – including fully organized trips but also combinations of two or more travel services such as combining a hotel stay with a rental car – offer a multitude of consumer rights, compared to individually booked travel services. These rights are governed by the EU Package Travel Directive (PTD). The PTD was last reviewed in 2018 but is up for review again to reflect recent changes in the dynamic travel industry.
 
The objective of the study was to assess the performance of the PTD with specific focus on:

  • Analyzing the overall performance of the PTD in the EU. 
  • Investigating the implementation and the enforcement of the PTD in 10 selected Member States, namely CZ, DE, EL, ES, FI, FR, IT, NL, PL, RO.
  • Exploring the potential implications of the digitalization on the PTD fitness. 
  • Assessing consumers' awareness of the rights granted by the PTD.
  • Designing tailored policy recommendations for consideration by the IMCO Committee.

ConPolicy was tasked with the assessment of consumer awareness regarding their rights granted by the PTD. To this end, we conducted desk research, expert interviews, and stakeholder consultations.

The study found that the definitions of package travel services and linked travel arrangements (LTAs) require updating as they are not sufficiently clear or workable in practice. It also found that the law foresaw necessary information provision but that in practice information documents were often not read and not sufficiently understood. It was suggested that a Key Information Document, like it is used for insurance services, could improve the understanding of consumers‘ rights and obligations when travelling on a package.

Furthermore, the travel industry’s wide use of pre-payments is an issue. Having to pay up front leaves consumers often in a weak position when it comes to claiming refunds due to non-compliant services, following service changes and especially insolvencies. The study also uncovered that the legal framework provided by the PTD was generally good and fit-for-purpose. Nonetheless, consumers found it often difficult to enforce their rights. This is because they are regularly „ping-ponged“ between different points of contact and find it difficult to get travel organizers to assume their responsibilities.

The study was prepared to support the ongoing parliamentary work of the IMCO Committee on the Internal Market and Consumer Protection of the European Parliament.

The full study can be found here.

Project of

Project Manager

+49 (0)30 2359116-17 a.cerulli-harms@conpolicy.de

Dr. Otmar Lell Project Manager

+49 (0)30 2359116-19 o.lell@conpolicy.de