EXPLANATORY MEMORANDUM

1. CONTEXT OF THE PROPOSAL

1.1. Background

Tourism represents the third largest socioeconomic activity in the EU in terms of contribution to GDP and employment, after the trade and distribution and construction sectors. It is one of the few economic sectors which register continuous growth, in spite of economic and financial difficulties, presenting thereby a great potential to contribute to "Europe 2020", the EU's growth strategy for a smart, sustainable and inclusive EU economy.

With some 1.8 million businesses, primarily SMEs, this sector[1] employs approximately 3.3 % of EU workforce (about 8 million jobs) and generates about 2.9% of EU GDP. Taking into account the sectors linked to it[2], its indirect contribution is even greater: it is estimated to provide around 8.5% of all jobs (approximately 18.8 million people employed) and generates about 7.9% of the European Union's GDP[3]. Despite increasing competition from other regions of the world, the EU is the world's No 1 tourist destination, with 384.8 million international arrivals in 2011[4].

With the adoption of the Lisbon Treaty, the EU has now been given the competence to complement the action of the Member States in the tourism sector, in particular by promoting the competitiveness of Union undertakings in that sector[5].

In response to the new powers granted to it and to the need for new measures to stimulate EU growth, the Commission adopted a Communication in 2010 on a new political framework for tourism in Europe[6]. This framework outlines an ambitious set of actions aiming at (a) stimulating competitiveness in the European tourism sector; (b) promoting the development of sustainable, responsible and high-quality tourism; (c) consolidating the image and profile of Europe as home to sustainable and high-quality destinations; and (d) maximising the potential of EU policies and financial instruments for developing tourism.

Action 13 of the Communication explicitly envisages the development of a European Tourism Quality Label, "based on existing national experience, to increase consumer security and confidence in tourism products and reward rigorous efforts by tourism professionals whose aim is quality of tourism service for customer satisfaction".

In its reaction to this Communication, the European Parliament called on the Commission "[…] to assess, in cooperation with tourism stakeholders, the feasibility of a European quality tourism label, […].in order to create an umbrella label complementary to national labels and recognised on an opt-in basis." [7] The 2009 study on the competitiveness of the EU tourism industry has found that even though the total number of international arrivals in Europe is still growing, Europe has been losing market share lately against new, emerging destinations worldwide. Moreover, globalisation, the Internet and rapidly changing consumer behaviour, as well as a growing concern about the environmental footprint of tourism activities have a strong impact on the industry[8].

In such an increasingly competitive market, the significance of quality has grown for tourism businesses, which are ever more aware of the importance of quality as a source of competitive advantage. Therefore access to reliable, up-to-date, accurate and relevant information on the quality of a particular tourism service is essential for tourists in order to differentiate among competing products and to make an informed choice.

This may be particularly accentuated in case of tourists arriving from another EU Member State, where uncertainties may be highlighted by linguistic difficulties, where information is not available in a language that the consumer understands.

Furthermore, given the current economic crisis, the EU must do all in its power to attract third country visitors. Ensuring that these visitors can rely on receiving a certain quality level of service across the EU is of paramount importance.

The information provided to consumers on the quality of tourism services has a role to play in attracting third country visitors, which has a huge and so far largely untapped potential to boost tourist arrivals to EU destinations and to enhance the competitiveness of EU tourism. In 2011 foreign visitor spending amounted to €330.44 billion. According to recent estimations these figures are likely to increase up to 20.4 million jobs and €427.31 billion in 2022[9].

Therefore the current initiative must also be seen in the context of the Commission’ initiative to brand Europe in third countries[10] and within this the “Destination Europe 2020” initiative[11], as well as the EU visa policy[12] which facilitates the travel of non-EU nationals to the EU[13] to help Europe remain the world’s No 1 tourist destination.

1.2 Current state of play

Currently there is no specific legislation at EU level regulating the information provided to consumers on the quality of tourism services[14].

Certain existing information tools, such as on-line evaluation and comparison websites, can help consumers in their decision-making process provided they display transparent and reliable information.

Certain Member States operate national, sub-national or regional public quality schemes within their territories on a voluntary basis. There is also a wide variety of industry initiatives at regional, national or transnational level, which mostly focus on service quality aspects specific to their respective tourism sub-sectors or geographic area.

As it has been confirmed by the market analysis carried out in the context of the assessment of policy options accompanying this proposal[15], these quality schemes show significant diversity and therefore very little consistency when compared in respect of their sectoral scope, geographical coverage, governance, assessment methodology and evaluation criteria.

The vast number and diversity of the existing private and public quality schemes result in a highly fragmented market in terms of the evaluation of tourism service quality.

As a consequence of this fragmentation, cross-border tourists are not provided with consistent information to easily understand what the various quality schemes represent and to differentiate between competing services. This leads to confusion. This then limits the quality schemes' capacity to effectively inform consumers about the quality level of the tourism services offered, which impairs the consumers' ability to make informed choices particularly when travelling to another Member State or from third countries. Hence, they do not reward (possibly with more favoured choices or better reputation) those businesses that invest in quality. This situation discourages the industry, particularly SMEs with limited financial resources, from doing so. As a result, the EU tourism industry is prevented from fully capitalising on its competitive advantage in service quality and fulfilling its economic potential by raising the visibility of its service quality. Tourism stakeholders have not so far been successful in cooperating at EU level to reduce the inconsistency across the EU between existing or future quality schemes and there are no indications that any private or public initiative that would improve this situation is likely to emerge. Therefore it is most urgently needed to address fragmentation of the market at several levels. The existing fragmentation among quality evaluation systems generate confusion and can negatively affect the competitiveness of European tourism.

2. RESULTS OF CONSULTATIONS WITH THE INTERESTED PARTIES AND IMPACT ASSESSMENTS

2.1 Consultation process

Following the adoption of the 2010 Communication, the Commission started gathering information on the existing quality schemes with the help of Member States and industry stakeholders. Two workshops were organised during the course of 2011 to exchange information on the existing experiences and to exchange ideas about possible common quality principles for tourism services. Early 2011, the Commission set up an informal expert group with the participation of managers of existing public and private quality schemes and consumer representatives to provide assistance in the development of a draft concept. The vast majority of stakeholders participating in the workshops and the informal expert group agreed that the EU initiative should follow a bottom-up approach, building on and recognising the existing and future initiatives by the Member States and the industry. However, with regards to what the common principles should include, the stakeholders expressed diverse views. Furthermore, the inclusion of environmental sustainability issues in the principles also triggered some different views among stakeholders.

A targeted consultation was carried out in September-October 2011, seeking the views of a wider circle of stakeholders, consisting of the main European tourism associations and federations, related industry associations, consumer organisations as well as the Members States' authorities. This consultation produced the same results in terms of stakeholders' positions as the preliminary workshops described above.

Member States were also consulted during the regular meetings of the Commission's Tourism Advisory Committee and expressed divergent opinions: some Member States expressed strong support for the initiative, opposing obligations on public administrations to participate in the governance of such EU initiative, mainly reasoning with non-compliance with the principle of subsidiarity and the restrictions of the legal basis, as well as limited resources of the national authorities.

To widen the consultation of stakeholders and collection of expertise, the Commission organised an open conference in January 2012. The documentation and the report of this conference can be found on the Commission's website[16]. The discussions at the conference reflected no change in the views and positions of the private and public stakeholders.

A public consultation was carried out between May and July 2012 through “Your Voice in Europe”, DG Enterprise and Industry website on Europa and e-mails sent to a wide range of private and public stakeholders as well as Member States' representatives. Professional associations and federations and public administrations made up 90% of the more than 150 respondents. The remaining 10% were tourism enterprises, two thirds of which participate in a quality scheme. Tourism trade unions and the representatives of consumers were also actively involved in the consultation process. Most respondents agreed with the Commission's definition of the problem and with the need for an initiative by the EU in this area. The public consultation results are published on the Commission's website[17].

In the framework of the assessment of policy options a background study was conducted on the experience of businesses about participating in a quality scheme, where the input of the managers of a representative sample of the existing quality schemes and their member businesses provided useful insight to the assessment of the impacts of the proposed initiative[18].

2.2 Assessment of policy options

The Commission assessed various policy options in view of improving the consistency among the existing and future quality schemes and as a result the information provided to consumers.

Altogether seven policy options were considered among which four were examined in the assessment. These include the option of no policy change, an industry-driven self-regulatory option and two options involving EU intervention. The latter two options examined the impacts of the possibility of including in the concept certain principles, such as those related to environmental sustainability aspects. The estimated economic, social and environmental impacts of each option were assessed based on their effectiveness in fulfilling the policy objectives, their cost-efficiency and their consistency with other EU policies.

The assessment paid particular attention to the fact that, participation by industry in either the option proposing self-regulation or the one suggesting EU intervention would be voluntary. Thorough consideration was also given to the conservation of the uniqueness and diversity of the European tourism offer, especially in view of the vast variety of tourism sub-sectors to which European service quality principles could be applied.

The assessment does not conclude on one sole favourable option as the comparison of options showed equal effectiveness, efficiency and consistency both for the option including only service quality-related principles and for the one extending information to other aspects, such as environmental sustainability.

3. LEGAL ELEMENTS OF THE PROPOSAL

3.1 Legal Basis

The proposal is based on Articles 195 and 292 TFEU.

3.2 Principle of subsidiarity and proportionality

Article 195 TFEU provides that the EU shall "complement the action of the Member States in the tourism sector, in particular by promoting the competitiveness of Union undertakings in that sector". In line with the principle of subsidiarity, the proposed EU action would be of a voluntary nature. The proposed initiative does not eliminate any existing initiative put in place by Member States or the industry.

The rationale for an EU action stems from the trans-national nature of the problem. This occurs in a cross-border setting, where the tourism service is provided in a country where the tourist is not resident, limiting the added value that quality schemes can provide for cross-border travellers, even more so when those travellers come from outside the EU.

The current situation (described under 1.2) concerning the evaluation of tourism service quality in Europe is not conductive to an adequate level playing field in the EU Industry. The inconsistency of quality evaluation schemes for tourism services at national and regional level confuses the consumers and creates obstacles to the internal market.

There is limited power and scope for the individual Member States to act alone in trying to improve consistency of the quality of tourism services offered across the EU. Member States have so far not initiated any cross-border coordination of tourism quality principles and there is no indication that they would do so in the future. Given the current low number of existing public schemes at national level, such cooperation would in any event not result in large scale cross-border cooperation. Moreover, individual Member States are currently not in a position to improve consistency between private schemes from other Member States. Therefore EU action is necessary and justified.

In addition, actions undertaken by the industry, even at transnational level are limited to a specific sub-sector (or maybe a few related ones), but are not of true horizontal scope. This results in inconsistent information being offered to consumers, as well as limits to the informative power of quality schemes and their member businesses in an intra-EU cross border context and towards travellers from third countries. This situation is not expected to change, requiring action at EU level.

For reasons of scale, the EU is better placed to tackle the problems of sectoral and geographic fragmentation described above. An EU framework pursuing the general interest of promoting the Union's tourism competitiveness would be more effective in terms of cross-border visibility and credibility. This can be achieved by complementing the work already undertaken by public and private tourism actors, encouraging and creating a favourable environment for them to combine their efforts. European Tourism Quality Principles can better be promoted by EU action, both in the Member States and towards travellers from third countries, as part of the overall EU promotional strategy in tourism. The added value of a large-scale action coordinated at EU level has been confirmed by a clear majority of stakeholders.

Finally, the proposal complies with the proportionality principle. The initiative was developed in view of limiting its costs to what is necessary to achieve the policy objectives. The application of the proposed quality principles mainly requires organisational change, which entails limited investments, that are expected to be balanced out by the benefits stemming from the increased satisfaction of consumers and from complementary EU actions.

To ensure that the competences of the Member States are respected it is recommended that the Member States coordinate, monitor and promote the application of the European Tourism Quality Principles in their respective territories, in cooperation with the Commission. With these measures the proposal duly respects the principle of subsidiarity.

3.3 Outline of the proposal

3.3.1 Subject matter and Objectives

The European Tourism Quality Principles set out in this proposal are applicable to tourism services offered in the Union directly to consumers and are recommended to be followed by public and private organisations providing services in the field of tourism.

The initiative aims to improve information to consumers, especially to those who travel to another Member State or from a third country, on the quality of tourism services, allowing quality-sensitive consumers to make better informed choices. This in turn strengthens incentives for EU tourism businesses, particularly for SMEs, to further invest in quality. It aims to do so by improving consistency in the quality of tourism services at EU level by setting European principles for tourism organisations to comply with. These principles originate from the criteria proposed by the stakeholders and assessed in the open consultation.

In operational terms, the aim is, by the time of the revision of the initiative, to have a significant number of tourism organisations in the EU following the European Tourism Quality Principles.

The added value of the initiative will be many-fold: a) tourism organisations that follow these Principles will be able to benefit from promotional and awareness raising action carried out by the Commission. This will lead to increased visibility, which will enhance their capacity to reach out to consumers and will provide them with the possibility to extend their activities to markets that they otherwise could not reach, in particular in third countries; b) For consumers, the added value will be the reassurance that certain European quality principles will be fulfilled, no matter which Member State they visit. Finally, highlighting and emphasising on the high quality of European tourism services will contribute to the overall EU strategy of improving tourism flows of travellers within and from outside Europe, complementing the efforts of facilitating visa requirements for third-country tourists as well as branding Europe as a set of sustainable and high-quality destinations.

Ultimately, this will contribute to the improved competitiveness of the sector and boost its capacity to create economic growth and jobs, to the benefit of Member States and the overall EU economy.

3.3.2 Application of the European Tourism Quality Principles

Sectoral and geographic scope

In order to achieve a better consistency of the quality of the tourism services across the EU, the European Tourism Quality Principles can be applied, without sub-sectoral restriction, to all those public or private tourism organisations that operate at national, regional, local or transnational level, offering tourism services in the Union to consumers.

Coordination, monitoring and promotion

In accordance with the principle of subsidiarity, Member States will be invited to coordinate, monitor and promote the European Tourism Quality Principles in respect of their territories.

Member States will also be recommended to cooperate between each other in respect of transnational tourism organisations. They will also be invited to cooperate with the Commission within the framework of the Tourism Advisory Committee, in order to facilitate the monitoring and assessment of the initiative, which might be undertaken, inter alia, with dedicated surveys among Member States, industry representatives and consumers.

The Programme for the Competitiveness of Enterprises and SMEs (COSME) 2014-2020, sets the specific objective to improve the framework conditions of the competitiveness and sustainability of Union enterprises in the tourism sector. With the objective of improving the image and profile of Europe as a sustainable, responsible and high-quality destination, the Commission will undertake information, communication and promotional activities, including the creation of a dedicated website providing information on the European Tourism Quality Principles. The Commission will also facilitate the exchange of best practice and experiences.

3.3.3 Evaluation

An evaluation of the implementation of this Recommendation is foreseen after three years following its publication in the Official Journal. The Commission will also assess whether further measures are necessary to enhance consistent service quality in tourism.

4. BUDGETARY IMPLICATIONS

An appropriate budgetary allocation could be foreseen for the promotion of the European Tourism Quality Principles, via the Competitiveness of enterprises and SMEs Programme (COSME)[19].

2014/0043 (NLE)

Proposal for a

COUNCIL RECOMMENDATION

on European Tourism Quality Principles

THE COUNCIL OF THE EUROPEAN UNION,

Having regard to the Treaty on the Functioning of the European Union, and in particular Articles 195 and 292 thereof,

Having regard to the proposal from the European Commission,

Whereas:

(1) The Commission recognises in its Communication of 30 June 2010, "Europe, the world's No 1 tourist destination – a new political framework for Europe"[20] the need to promote the development of sustainable, responsible and high-quality tourism, as part of the overall objective of promoting the Union as a collection of high-quality destinations in third countries.

(2) The promotion of high environmental performances of tourism accommodations and campsites and best environmental management practices of the tourism sector are already specifically addressed at Union level through the application of Regulation (EC) No 66/2010 of the European Parliament and of the Council[21] and by Regulation (EC) No 1221/2009 of the European Parliament and of the Council[22].

(3) A wide variety of public and private quality schemes already exists in the Union, aiming at providing information to consumers on the quality of tourism services and providing guidance to tourism professionals. Those schemes show significant diversity in scope, governance, methodology and criteria. Moreover, their operation is limited to certain sub-sectors or geographic areas, which results in a highly fragmented environment in respect of the evaluation of tourism service quality.

(4) Because of this fragmentation and the lack of consistent assessment across the existing quality schemes, consumers travelling cross-border within the Union or to the Union from third countries may find it difficult to compare the services covered by different quality schemes. That lack of consistency limits the consumers' capacity to make fully informed choices.

(5) Due to the lack of consistent assessment across the existing quality schemes, tourism businesses have so far had limited capacity to gain visibility vis-à-vis consumers and to benefit from coordinated actions. This is especially true for micro and small enterprises which often do not have the adequate tools and resources to promote themselves and the high-quality service they provide.

(6) In order to boost the tourism industry's competitiveness, it is necessary to make the Union's tourism businesses attractive for third country nationals.

(7) It is therefore appropriate to outline a set of European Tourism Quality Principles acknowledged by consumers and the industry.

(8) In order to ensure the coverage of the largest possible range of tourism subsectors and at the same time to preserve the diversity of the Union's tourism offer, the European Tourism Quality Principles should be of general nature, but offer an added value in line with consumers' expectations towards high quality tourism services.

(9) To ensure the satisfactory provision of tourism services, it is necessary to provide adequate training to the relevant employees on the tasks assigned to them. The same reason prompts that the attended training is recorded in a training register.

(10) To facilitate continuous improvement of tourism service quality to meet the requirements of consumers, it is important to carry out consumer surveys and ensure a response to complaints.

(11) To promote the authenticity and diversity of the Union’s tourism offer, it is necessary that consumers are provided with up-to-date information on local customs, heritage, traditions, services and products.

(12) To enhance the awareness about the European Tourism Quality Principles, and therefore gain consumer confidence, it is key that tourism organisations provide information and guidance related to those Principles to consumers.

(13) In order to facilitate the application of the European Tourism Quality Principles within their territories as well as the coordination of their actions, Member States should coordinate, monitor and promote the European Tourism Quality Principles in a transparent manner.

(14) In order to ensure that the European Tourism Quality Principles are applied on a voluntary basis by tourism organisations operating in more than one Member State (transnational organisations), it is essential that Member States cooperate with each other in view of the application of the European Tourism Quality Principles by those organisations.

(15) In order to facilitate the consistent application of the European Tourism Quality Principles and of their coordination, monitoring and promotion throughout the Union, the Member States are invited to exchange information and experiences. The Commission should facilitate such exchange of information.

(16) To complement the action of the Member States in promoting the competitiveness of the tourism sector, it is important to inform the consumers and raise their awareness of the European Tourism Quality Principles through appropriate promotional and information actions within the Union, but also and in particular in third countries, in view of the objective of promoting the Union as a collection of high-quality destinations. Moreover, in order to encourage the creation of a favourable environment for the development of the tourism sector, it is also important to make the European Tourism Quality Principles attractive to tourism organisations. It is therefore important that the Member States and the Commission cooperate in this respect.

(17) To facilitate the monitoring and assessment of the application of the European Tourism Quality Principles, the Member States have a strong role by informing the Commission of the application of the European Tourism Quality Principles in their territories, in particular within the framework of the Tourism Advisory Committee meetings.

(18) To respond to the rapidly changing market conditions in the area of tourism and to ensure the added value of the European Tourism Quality Principles in the long term, the Commission should monitor their application and should evaluate the implementation of this Recommendation after three years of its publishing in the Official Journal of the European Union. For the same reason the Commission should also assess whether additional measures are needed to ensure the achievement of the objectives reflected in this Recommendation,

HEREBY RECOMMENDS:

1. Subject matter and scope

This Recommendation lays down a set of European Tourism Quality Principles (hereinafter referred to as "Principles") to be applied by tourism organisations.

2. Definitions

For the purposes of this Recommendation the following definitions shall apply:

(a) 'tourism organisation' means a public or private organisation, established in the Union and providing services to consumers in the field of tourism at local, regional, national or transnational level;

(b) 'transnational tourism organisation' means a tourism organisation carrying out activities in the territory, or parts thereof, of more than one Member State.

3. European Tourism Quality Principles

Where appropriate to the size and business concept, tourism organisations are recommended to apply the following Principles to their activities:

(a) Ensure the training of employees, including the following:

i) training of all employees involved in the provision of services directly to consumers to ensure the satisfactory delivery of the tasks assigned to them;

ii) recording the attended training by the employees in a training register established for this purpose;

iii) appointment of a quality coordinator in order to ensure a coherent approach towards the quality management of the services provided and the involvement of the relevant employees in the quality process;

(b) Apply a consumer satisfaction policy, including the following:

i) establishment of a mechanism for the handling of consumers' complaints at the place of the delivery of the service or via the Internet;

ii) ensuring that complaints are responded to without delay;

iii) carrying out consumer satisfaction surveys and the taking into account the results thereof to improve the quality of the service;

(c) Keep and adhere to a documented cleaning and maintenance plan for the facilities or equipment where appropriate;

(d) Make information available to consumers, including the following:

i) information on local customs, heritage, traditions, services and products;

ii) information on accessibility with respect to the services provided;

iii) information on sustainability aspects with respect to the services provided;

iv) information on the Principles;

(e) Ensure that this information is correct, reliable, clear and accessible in at least the most relevant foreign language, if appropriate to the location and business concept.

4. Activities by the Member States

4.1. Member States should coordinate, monitor and promote the application of the Principles within their respective territories. For those purposes, Member States are invited to:

(a) monitor the application of the Principles set out in point 3 by tourism organisations;

(b) coordinate with the other Member States, the activities related to the Principles and their application;

(c) promote the Principles among tourism organisations;

(d) ensure, in cooperation with the other Member States, that adequate information and guidance on the Principles is made available to tourism organisations;

(e) cooperate with each other in order to facilitate the application of the Principles by transnational tourism organisations.

4.2. It is also recommended that the conduct of the Member State's activities guarantees transparency.

5. Cooperation between the Member States and the Commission

Member States are invited to inform the Commission of the activities referred to in point 4 and to cooperate with the Commission in view of their monitoring and assessment, as well as of their awareness raising and promotional initiatives.

6. MonitorinG and assessment

6.1. The Commission should assess the implementation of this Recommendation by [date to be defined 3 years after the publication of the Recommendation in the Official Journal]

6.2. The Commission should also assess whether further measures to improve the consistency of tourism service quality in the Member States reflected in this Recommendation should be proposed.

7. Final provisions

This Recommendation shall be published in the Official Journal of the European Union.

Done at Brussels,

For the Council

The President

[1] Traditional suppliers of travel and tourism services (hotels, restaurants, travel agencies, car hire, charter airlines, tourist coaches, cruise vessels, etc.) offering goods and services directly to visitors.

[2] In particular distribution, construction, transport companies in general (air, rail, maritime, bus/coach, etc.) and the cultural sector (including cultural and creative industries).

[3] WTTC 2012 http://www.wttc.org/site_media/uploads/downloads/european_union2012.pdf

[4] UNWTO World Tourism Barometer, May 2012.

[5] Article 6(d) of the "Treaty for the functioning of the European Union". Further to this, Article 195 TFEU provides for the EU "To that end, Union action shall be aimed at (a) encouraging the creation of a favourable environment for the development of undertakings in this sector; (b) promoting cooperation between the Member States, particularly by the exchange of good practice".

[6] Europe, the world's N°1 tourist destination – a new political framework for tourism in Europe COM(2010) 352 final.

[7] P7_TA-PROV(2011)0407 – European Parliament Resolution of 2709/2011 on Europe, the world's No 1 tourism destination – a new political framework for tourism in Europe.

[8] Ecorys (2009), p. 2.

[9] http://europa.eu/rapid/press-release_IP-12-1177_en.htm

[10] COM (2010)352 final foresees the creation of a “Europe” brand, to complement promotional efforts at national and regional level and enable European destinations to distinguish themselves from other international destinations (action 18)

[11] Carried out under an ad-hoc grant in cooperation with the European Travel Commission, with the overall objective of defining a branding and marketing strategy for Destination Europe http://ec.europa.eu/enterprise/sectors/tourism/international/index_en.htm

[12] COM(2012) 649 final

[13] There are currently 42 countries and entities whose citizens do not need a visa to travel to the EU. Citizens from 16 Caribbean and Pacific Island Nations should soon be able to travel to the Schengen area without needing a visa. The objective is to simplify travel to the Schengen area, as well as to Cyprus, Bulgaria and Romania for citizens of these countries. The Commission's proposal foresees that the visa exemption will be reciprocated through visa waiver agreements, ensuring a full visa free regime for all EU citizens who wish to travel to these countries. http://europa.eu/rapid/press-release_IP-12-1179_en.htm?locale=en

[14] General EU consumer protection legislation already exists, for example Directive 2011/83/EU on Consumer Rights.

[15] Estimated Impacts of possible Options and Legal Instruments of the Umbrella European Tourism Quality Label, CEPS, September 2012, available online at: http://ec.europa.eu/enterprise/newsroom/cf/_getdocument.cfm?doc_id=7655, hereinafter CEPS (2012).

[16] http://ec.europa.eu/enterprise/newsroom/cf/itemdetail.cfm?item_id=5642

[17] http://ec.europa.eu/enterprise/sectors/tourism/public-consultation-etq/index_en.htm

[18] CEPS (2012)

[19] Regulation Establishing a Programme for the Competitiveness of Enterprises and for SMEs 2014-2020, Regulation (EU) No 1287/2013, OJ L 347, p. 33.

[20] COM(2010) 352 final.

[21] Regulation (EC) No 66/2010 of the European Parliament and of the Council of 25 November 2009 on the EU Ecolabel (OJ L 27, 30.1.2010, p. 1).

[22] Regulation (EC) No 1221/2009 of the European Parliament and of the Council of 25 November 2009 on the voluntary participation by organisations in a Community eco-management and audit scheme (EMAS), repealing Regulation (EC) No 761/2001 and Commission Decisions 2001/681/EC and 2006/193/EC (OJ L 342, 22.12.2009, p. 1).