COMMISSION STAFF WORKING DOCUMENT Accompanying the document Report from the Commission to the European Parliament and the Council on the provisions of Directive (EU) 2015/2302 of the European Parliament and of the Council of 25 november 2015 on package travel and linked travel arrangements applying to online bookings made at different points of sale
Date: 2019-06-21
Institutions: Directorate-General for Justice, European Commission
Subjects: Internet, application of EU law, consumer information, electronic commerce, package travel, provision of services, reservation, traveller

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 21.6.2019  SWD(2019) 270 final  COMMISSION STAFF WORKING DOCUMENT Accompanying the document Report from the Commission to the European Parliament and the Council on the provisions of Directive (EU) 2015/2302 of the European Parliament and of the Council of 25 november 2015 on package travel and linked travel arrangements applying to online bookings made at different points of sale {COM(2019) 270 final}  
 
 
This  Staff Working Document presents  further background information  for the Commission 
Report  on  the  provisions  of  the  Package  Travel  and  Linked  Travel  Arrangements  Directive 
applying to online bookings made at different points of sale ('click-through' bookings)1. 

1.  Methodology 

The  national  measures  transposing  Directive  2015/2302  on  package  travel  and  linked  travel 
arrangements  (Package  Travel  Directive)2  started  applying  in  the  Member  States  on  1  July 
2018. 

In July 2018, the Commission’s Directorate-General Justice and Consumers set up an expert 
group on package travel and linked travel arrangements3 (“the Expert Group”). It is composed 
of  experts  representing  EU  business  organisations  active  in  the  travel  sector,  national/EU 
organisations  representing  consumers  and  travellers,  national  alternative  dispute  resolution 
bodies specialised in travel and tourism, and entities providing insolvency protection for the 
travel sector (see list of members in Annex 1).  

The  Expert  Group  assisted  in  the  design  and  the  distribution  of  the  questionnaires  for  the 
targeted  stakeholder  consultation  that  was  carried  out  in  October  and  November  2018. 
Altogether almost 200 contributions were received from the travel and tourism business. The 
airline  sector,  albeit  represented  in  the  Expert  Group,  did  not  provide  feedback  to  the 
stakeholder  consultation.  For  further  details  on  the  number  of  contributions  received,  see 
Annex 2. The Expert Group and the competent  enforcement  authorities were also  consulted 
on a draft version of the report.4 

In parallel, the national data protection authorities were consulted, through the Secretariat of 
the  European  Data  Protection  Board,  on  the  data  protection  aspects  of  the  relevant 
provisions5.  

2.  Transposition of the Package Travel Directive in the Member States 

The  Member  States  had  to  transpose  the  Package  Travel  Directive  by  1  January  2018.  The 
infringement  procedures  against  14  Member  States  for  non-
Commission  opened 
communication  of  national  transposition  measures.  By  March  2019,  all  Member  States  had 
notified the Commission of the complete transposition of the Directive. Most Member States 

1   Report from the Commission to the European Parliament  and to the Council on the provisions of Directive 
(EU) 2015/2302 of the European parliament and of the Council of 25 November 2015 on package travel and 
linked travel arrangement applying to online booking made at different points of sale.  [COM(2019)270] 
2   Directive (EU) 2015/2302 of the European parliament and of the Council of 25 November 2015 on package 
travel and linked travel arrangement, amending regulation (EC) N° 2006/2004 and Directive 2011/83/EU of 
the  European  parliament  and  of  the  Council  and  repealing  Council  directive  90/314/EEC,  OJ  L  326  of 
11.12.2015, p. 1.  

3   Stakeholder expert group to support the application of the Package Travel and Linked Travel Arrangements 

Directive (2015/2302) (E03617)  
http://ec.europa.eu/transparency/regexpert/index.cfm?do=groupDetail.groupDetail&groupID=3617&NewSea
rch=1&NewSearch=1 

4   Through  the  Consumer  Protection  Cooperation  (CPC)  network  and  at  the  Expert  Group  meeting  of  25 
available 

January 
http://ec.europa.eu/transparency/regexpert/index.cfm?do=groupDetail.groupMeeting&meetingId=11510 
5    Nine  replies  received  from  Cyprus,  Germany,  Estonia,  Greece,  Ireland,  Lithuania,  Latvia,  Malta  and 

minutes 

2019, 

Slovakia.  

1 

 
 
                                                           
used the same wording as the Directive when transposing Articles 3(2) and 3(5), containing 
the definitions of ‘package’ and ‘linked travel arrangement’.   

Some  Member  States  adopted  additional  provisions6  or  guidance  documents7  aimed  at 
clarifying certain concepts. In some cases, such guidance documents refer to the discussions 
held in the transposition workshops organised by the Commission8.  

Most Member States reproduced in their national legislation9 the standard information forms 
set  out  in  the  annexes  of  the  Directive  which  operators  must  use  for  the  pre-contractual 
information  of  travellers  in  the  case  of  package  travel  contracts  (Article  5;  Annex  I)  and 
linked travel arrangements (Article 19; Annex II).  

Apart  from  late  transposition,  no  prima  facie  problems  related  to  the  transposition  of  the 
Directive’s  provisions  relevant  for  'click-through’  booking  have  been  identified  so  far.  The 
Commission  has  started  a  systematic  assessment  of  the  conformity  of  the  national 
transposition measures with the Directive in April 2019. The results will be considered for the 
general report on the implementation of the Directive due by 2021.  

3.  Different forms of linked online travel booking processes 

3.1. Packages purchased online from different points of sale   

Article 3(2) of the Package Travel Directive contains the definition of 'package'. Its point (b) 
describes  five  scenarios  that  lead  to  the  creation  of  a  package  which  apply  irrespective  of 
whether  separate  contracts  are  concluded  with  individual  travel  service  providers.  While 
packages  “offered,  sold  or  charged  at  an  inclusive  or  total  price”  (Article  3(2)(b)(ii))  or 
“advertised or sold as a 'package' or under a similar term” (Article 3(2)(b)(iii)) could, at least 
theoretically, also be booked online at different points of sale, they are usually purchased at a 
single point of sale (e.g. on the package organiser's website) and are not covered by the report.    

Article  3(2)(b)(v)  specifically  covers  the  situation  of  a  ‘click-through’  booking  involving 
different points of sale:  
’package’  means  a  combination  of  at  least  two  different  types  of  travel  services  for  the 
purpose of the same trip or holiday, if:  

6    E.g.  the  German  law  (§651w,  Absatz  1,  2.  Unterabsatz,  BGB)  provides  that  “facilitation  in  a  targeted 
manner” of a linked travel arrangement shall not apply if the trader merely puts the traveller in contact with 
another  trader  and  the  amended  Italian  Legislative  Decree  No  79  of  23  May  2011  provides  that 
“supplementary travel service means ancillary services such as, inter alia, transport of luggage provided as 
part of carriage of passengers; use of pay and display parking at stations or airports; carriage of passengers 
for short distances as part of a guided tour or transfers between an accommodation facility and a travelling 
station by other means; organisation of entertainment or sporting activities; provision of meals, drinks and 
cleaning  provided  in  the  context  of  accommodation;  use  of  bicycles,  skis  and  other  equipment  from  the 
accommodation  facility  or  access  to  on-site  facilities  such  as  swimming  pools,  beaches,  gyms,  saunas, 
wellness  centres  or  spas,  including  for  hotel  guests;  any  other  typical  supplementary  service  according  to 
local customs”. 

7   E.g.  Guidelines, Loi du 21 novembre 2017 relative à la vente de voyages à forfait, de prestations de voyage 
liées  et  de  services  de  voyage  (BE),  LU  guidelines  and  Package  Travel  and  Linked  Travel  Arrangements 
Regulation 2018 Guidance for Business (UK). 

8   The  Commission  services  held  5  workshops  with  Member  States  to  discuss  the  transposition  of  the  PTD. 
these  meetings  are  publicly  available  here  https://ec.europa.eu/newsroom/just/item-

Minutes  of 
detail.cfm?item_id=35324.   

9   Sweden has not yet communicated the standard forms for which the Swedish Consumer Agency has received 

the powers to adopt them.  

2 

 
 
 
 
 
 
 
 
                                                           
[…]  

  purchased  from  separate  traders  through  linked online  booking  processes  where  the 
traveller's name, payment details and e-mail address are transmitted from the trader 
with whom the first contract is concluded to another trader or traders and a contract 
with  the  latter  trader  or  traders  is  concluded  at  the  latest  24  hours  after  the 
confirmation of the booking of the first travel service.  

The aim of the Commission Report and this Staff Working Document is precisely to analyse 
whether  this  provision  should  be  adjusted  or  broadened.  The  following  chart  illustrates  the 
relationship between the two traders involved in the linked online booking process.  

Click-through package – Art. 3 (2)(b)(v)

3.1.1.  Click-through packages in application of Article 3(2)(b)(v) 

According to Article 5 of the Directive, organisers of packages must provide travellers with 
the  standard  information  by  means  of  the  relevant  form  as  set  out  in  the  Annex  I  of  the 
Directive.    

In case of ‘click-through’ packages within the meaning of Article 3(2)(b)(v), organisers have 
to use Part C of Annex I. This form being exclusively used for this specific type of package, 
feedback  on  its  use  would  be  an  indication  of  the  extent  to  which  operators  offer  ‘click-
through’ packages as defined in Article 3(2)(b)(v).  

3 

Trader 1« organiser »Trader 2contract 1contract 2within 24h of booking confirmation of contract 1TravellerStandard information form to traveller (Annex I, part C)Linked online booking processInformation about conclusion of contract 2 with same travellerInformation about traveller (name e-mail and payment details)  
 
 
 
 
In replies to the questionnaires, several trade associations indicated that their members do not 
offer  ‘click-through’  packages.  Hence,  they  do  not  use  the  form  set  out  in  Part  C  of  the  
Annex I.  

Other  trade  associations  indicated  that  their  members  would  offer  click-through  packages, 
using either the standard information form for packages defined in Article 3(2)(b)(ii) and (iii) 
(i.e. part A of the Annex I) or, sometimes, for packages defined in Article 3(2)(b)(v) (part C 
of the Annex I). However, these trade associations also indicated that their members usually 
do  not  transfer  the  traveller’s  personal  data  (name,  email  address  and  payments  details)  to 
another trader while this is  a requirement for  ‘click-through’ packages  as defined in  Article 
3(2)(b)(v).  These  somehow  contradictory  replies  may  be  due  to  a  misunderstanding  of  the 
questionnaire as well as little experience with the use of the new standard information forms. 
As  to  the  first  point,  some  respondents  may  have  considered  the  selection  (by  means  of 
‘clicking’) of several travel  services on the same website  as a  ‘click-through’ booking  even 
though the travel services are purchased from a single point of sale and would therefore not 
qualify  as  a  linked  online  booking  process.  As  regards  the  use  of  information  forms,  the 
organiser of a package within the meaning of Article 3(2)(b)(ii) or (iii) must use the standard 
information form set out in part A of Annex I even in the, rather theoretical, case of a ‘click-
through’ booking from different points of sale.  

Competent  authorities  and  alternative  dispute  resolution  bodies10  have  not  reported  about 
queries or  complaints  regarding the use of any of the standard information forms  for  'click-
through’  bookings  and  no  enforcement  action  has  been  undertaken  in  this  respect  so  far, 
possibly due to the short period of time since the application of the new rules.  

Whilst some data protection authorities received queries related to the application of the new 
General Data Protection Regulation11 in the travel or tourism sector, they did not report about 
queries  or  complaints  in  relation  to  the  data  protection  related  provisions  of  the  Package 
Travel  Directive12.  Alternative  dispute  resolution  bodies  or  competent  authorities  for 
enforcement  of  the  Package  Travel  Directive  did  not  report  about  queries  or  complaints 
related  to  data  protection  within  the  framework  of  the  application  of  the  Package  Travel 
Directive either.  

From this feedback, one might conclude that the offer of ‘click-through’ packages within the 
meaning  of  sub-paragraph  (v)  of  Article  3(2)(b)  appears  to  be  a  rather  rare  phenomenon. 
However,  in  the  absence  of  feedback  from  the  airline  sector  to  the  stakeholder  consultation 
further  studies  are  necessary  to  have  a  clearer  picture  of  the  prevalence  of  ‘click-through’ 
packages on the market. 

10   Directive 2013/11/EU of the European Parliament and of the Council of 21 May 2013 on alternative dispute 
resolution for consumer disputes and amending Regulation (EC) No 2006/2004 and Directive 2009/22/EC, 
OJ L 165, 18.6.2013, p. 63–79. 

11   Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection 
of natural persons with regard to the processing of personal data and on the free movement of such data, and 
repealing Directive 95/46/EC, OJ L 119, 4.5.2016, p. 1–88. 

12   Nine  replies  received;  only  Greek  authority  received  request  for  presentation  on  General  Data  Protection 

Regulation by the Hellenic Chamber of Hotels.  

4 

 
 
                                                           
3.1.2.  Adjustment or broadening of the definition of ‘click-through’ 

booking of a package in Article 3(2)(b)(v)  

Most  of  the  consulted  stakeholders  either  had  no  opinion  yet  regarding  a  possible 
modification of the definition in Article 3(2)(b)(v) or were against it, as it would be too early 
to  take  a  well-informed  decision  in  light  of  the  limited  practical  experience  with  the 
application of the new rules. In addition, the Expert Group concluded that it was too early to 
draw  conclusions  regarding  a  possible  adjustment  or  broadening  of  the  definition.  Some 
members  of  the  Expert  Group,  however,  specified  that  this  should  not  be  understood  as  an 
endorsement  of  the  definitions  and  the  specific  rules  on  online  bookings  of  packages  and 
linked travel arrangements.  

Respondents  in  favour  of  a  modification  of  the  definition  considered  that  it  should  be 
broadened,  by  deleting  some  of  its  requirements  namely  the  need  for  a  transfer  of  payment 
details from one trader to the other, which would be extremely rare13.  

Among  authorities,  views  were  diverse.  Some  authorities  and  alternative  dispute  resolution 
bodies  would  support  broadening  the  definition  in  order  to  prevent  the  possibility  to 
circumvent the current definition and make enforcement easier, especially with regard to the 
24 hours rule. Other authorities would rather favour a more narrow definition (with additional 
requirements) or even a deletion of Article 3(2)(b)(v) as they considered it as too complex and 
hardly used. 

The  Expert  Group  highlighted  that  rather  than  the  definition  itself,  it  is  the  delimitation 
between packages booked online from a single point of sale (and not through a linked online 
‘click-through’ booking process) and the facilitation of the separate selection and payment of 
travel  services  in  the  form  of  a  linked  travel  arrangement  which  is  challenging  for  the 
industry, but also for consumers who may not be aware of the change brought by the Package 
Travel Directive. 

3.2. Qualification of online bookings made at different points of sale as package 

or linked travel arrangement  

The  operator  must  inform  the  traveller  whether  he/she  is  about  to  conclude  a  package  or  a 
linked travel arrangement.  

If not a package, online booking of travel services at different points of sale may be qualified 
as  linked  travel  arrangement  within  the  meaning  of  Article  3(5)  of  the  Directive.  A  linked 
travel  arrangement  can  either  be  concluded  through  the  separate  selection  and  payment  of 
travel  services  on  the  occasion  of  a  traveller's  single  visit  or  contact  with  his  point  of  sale 
(Article 3(5)(a) - not relevant for the report) or when a "trader facilitates […] in a targeted 
manner, the procurement of at least one additional travel service from another trader where a 
contract with such other trader is concluded at the latest 24 hours after the confirmation of 

13   In particular, the ECTAA (representing European travel agents and tour operators associations) emphasised 

that there is no or extremely few transfer of payment details between traders. 

5 

 
 
 
 
                                                           
the booking  of  the first travel  service"  (Article 3(5)(b)  -  click-through  LTA relevant  for the 
report).  

Recital  12  of  the  Directive  clarifies  in  this  respect  that  “online  linked  travel  arrangements 
should  […]  be  distinguished  from  linked  websites  which  do  not  have  the  objective  of 
concluding a contract  with the traveller and from links through which travellers  are simply 
informed  about  further  travel  services  in  a  general  way,  for  instance  where  a  hotel  or  an 
organiser of an event includes on its website a list of all operators offering transport services 
to  its  location  independently  of  any  booking  or  if  ‘cookies’  or  meta  data  are  used  to  place 
advertisements on websites.” 

The  following  chart  illustrates  the  relationship  between  the  two  traders  in  a  linked  travel 
arrangement that is facilitated in a targeted manner.  

Click-through LTA – Art. 3 (5)(b)

It  is  noteworthy  that  most  providers  of  insolvency  protection  that  responded  (e.g.  insurers, 
guarantee funds) do not differentiate between packages and linked travel arrangements (being 
click-through or not) for the purpose of securing their clients14. According to them, there is no 
relevant difference in the financial risk to be covered for these two types of combinations in 
case  of  insolvency.  Providers  of  insolvency  protection  consider  that  they  do  not  yet  have 
sufficient data or tools to determine the different risks for packages versus LTAs. 

14   Some insurers, however, do make such differentiation.  

6 

Trader 1Trader 2TravellerStandard information form to traveller (Annex II, part D or E)Facilitation in a targeted mannerInformation about conclusion of contract 2 with same traveller (art. 19.4)Information about traveller (name or e-mail ...) or anonymised way of trackingcontract 2within 24h of booking confirmation of contract 1contract 1 
 
 
 
                                                           
3.2.1.  Challenges in relation with ‘click-through’ linked travel 

arrangements 

Based  on  discussions  within  the  Expert  Group  and  stakeholders’  feedback,  one  of  the  key 
challenges  related  to  the  new  concept  of  linked  travel  arrangements  is  the  lack  of  clarity 
regarding the meaning of “facilitation in a targeted manner” and the determination whether or 
not  a  second  trader  has  concluded  a  contract  with  a  traveller  within  24  hours  after  the  first 
contract.  

As regards “facilitation in a targeted manner”, there is uncertainty whether or not it requires 
an active promotion of the second transaction by the facilitating trader and whether or not the 
provision of relevant (general) advertisements is covered by this concept.  

The  practical  challenge  how  to  determine  whether  a  contract  with  a  second  trader  has  been 
concluded within 24 hours concerns the information exchange between the first trader (i.e. the 
one  facilitating  the  procurement  of  an  additional  travel  service)  and  the  second  trader. 
According  to  Article  19(4)  of  the  Package  Travel  Directive,  the  second  trader,  upon 
conclusion of a contract with a traveller within 24 hours of the first contract, must inform the 
first trader of the conclusion of the second travel service. To that end, the first trader should, 
in  practice,  inform  the  second  trader  that  he  has  concluded  a  contract  with  the  traveller 
beforehand,  even  though  such  information  obligation  is  not  expressly  laid  down  in  the 
Directive.  

It  was however reported that the second trader often is  either not  aware of his  obligation to 
share such information, lacks the appropriate technology to track and identify the first trader 
or is reluctant to inform the first trader about the conclusion of a contract with a traveller for 
business reasons as this may increase the price that the first trader requests for the link.  

Other  factors  invoked  are  the  complexity  of  booking  in  cascade  involving  three  or  more 
traders, terminology used in national legislations and uncertainty about the legal basis for the 
transfer of some personal data.  

Two  members  of  the  Expert  Group  reported  that  some  of  their  members  send  anonymised 
information  about  travel  destination,  dates  and  types  of  travel  service  to  the  second  trader. 
However,  the  majority  of  hotels  who  contributed  do  not  send  any  information  about  the 
contract concluded with a traveller because they do not know if a second contract is actually 
concluded.  

3.2.2.  Coping with challenges in relation to ‘click-through’ bookings  

In order to address the challenges related to ‘click-through’ bookings, a large number of travel 
and  tourism  operators  indicated  that  they  have  re-assessed  existing  partnerships  with  other 
traders  or  are  in  the  process  of  doing  so,  in  order  to  ensure  that  they  exchange  information 
with partners they can trust and who have the technological capacity.  

7 

 
 
 
 
 
The new rules also appear to have led to changes in the design of traders’ websites (e.g. tabs 
presentation)  and  the  provision  of  additional  information  to  the  one  that  is  mandatory.  One 
Expert Group member also reported about the creation of a separate company specifically for 
online bookings.  

Several  participants  in  the  Expert  Group  pointed  out  that  some  of  their  members  ceased  to 
offer the possibility of ‘click-through’ booking of travel services offered by another trader or 
limited the promotion of third party services  for  fear of  falling inadvertently into the linked 
travel arrangement category.  

In  addition,  alternative  dispute  resolution  bodies  reported  about  certain  changes  of  business 
practices, for example of hotels, related to uncertainties with regard to the concepts of "other 
tourist services" and "facilitation in a targeted manner". In order to avoid the risk to become 
subject  to  rules  on  linked  travel  arrangements,  a  number  of  traders  seem  to  have  stopped 
transferring  customers’  information  or  to  provide  links  on  their  website  to  other  service 
providers.  

Whilst  disputes  related  to  the  new  rules  are,  if  existing  at  all,  still  rare,  alternative  dispute 
resolution  bodies  and  authorities  pointed  out  that  enforcement  will  be  challenging.  Some 
mentioned  in  particular  that  verification  whether  the  two  contracts  are  concluded  within  24 
hours  would  be  almost  impossible.  Others  consider  that  the  distinction  between  ‘click-
through’  booking  of  a  package  or  of  a  linked  travel  arrangement  would  be  difficult  for  an 
authority to enforce. Some authorities consider the legislation too complicated for both traders 
and consumers. Therefore, traders would be unable to fulfil the requirements and consumers 
be unaware of their rights.  

There  is  therefore  a  strong  call  from  stakeholders  and  authorities  for  guidance  on  the 
application  of  the  current  rules  to  bring  more  clarity,  legal  certainty  and  uniformity,  which 
could be more helpful than legislative changes at this stage. In addition, although this was not 
raised during the stakeholder consultation and discussions in the expert group, the application 
of the Package Travel Directive to online intermediation services, comparison sites and search 
engines may also need to be further studied.  

8 

 
 
 
 
 
 
Members of the Stakeholder Expert Group to support the application of the Package 
Travel Directive15  

Annex 1 

EU-level or national organisations representing consumers and/or travellers 

  ULC (Union Luxembourgeoise des Consommateurs) 
  DECO (Portuguese Association for the consumer defence)  
  VzBv (Federation of German consumer organisations) 
  AK (Austrian Federal Chamber of Labour, Bundesarbeitskammer Österreich) 
  EPF (European Passengers’ Federation) 

EU-level business organisations  representing  traders active in the travel sector and involved 
in the provision of package travel and/or linked travel arrangements 

  ECTAA (The European Travel Agents' and Tour Operators’ Associations)  
  HOTREC (Hospitality Europe) 
  CER (The Voice of European Railways) 
  CLIA Europe (The Cruise Lines International Association) 
  ECSA (European  Community Shipowners' Association) 
  ETTSA (European Technology & Travel Services Association) 
  FITE  (International Federation of Equestrian Tourism) 
  ETOA (European Tourism Association aisbl)  
  EHHA (European Holiday Home Association) 
  Eurogites (European Federation of Rural Tourism) 
  A4E (Airlines for Europe) 

Organisations representing entities providing insolvency protection for the travel sector 

  GDV  (Gesamtverband  der  Deutschen  Versicherungswirtschaft  e.V.  -  German 

Insurance Association) 

National alternative dispute resolution bodies specialised in (package) travel and/or tourism 

  MTV Mediation Tourisme et Voyage 
  Tourism  Service  Board  –  Austrian  Federal  Ministry  of  Sustainability  and  Tourism 
(Bundesministerium für Nachhaltigkeit und Tourismus - Tourismus-Servicestelle) 

  Česká obchodní inspekce - ČOI (Czeck Trade Inspection Authority) 

15   The Expert Group is listed in the Commission's Register of Expert Groups under the reference E03617 

http://ec.europa.eu/transparency/regexpert/index.cfm?do=groupDetail.groupDetail&groupID=3617&NewSea
rch=1&NewSearch=1 

9 

 
 
 
 
 
 
 
 
 
 
 
 
 
                                                           
Annex 2 

Result of stakeholder consultation 

The  targeted  stakeholder  consultation  was  carried  out  during  the  period  October/November 
2018.  Questionnaires  were  addressed  to  travel  operators  and  providers  of  insolvency 
protection in the travel sector, consumers’/travellers’ organisations (members of BEUC16 and 
European  Passenger  Federation),  competent  authorities  responsible  for  enforcement  of  the 
Package Travel Directive17 and to alternative dispute resolution bodies.  

Addressees of the 
questionnaires  

Respondents 

Competent authorities 
responsible for 
enforcement of the PTD 

Alternative dispute 
resolution bodies 

Consumers’/travellers’ 
organisations  

Travel and tourism 
operators 

from 
Germany, 
Latvia, 
Slovenia, 
Republic, 
Finland, 
Luxembourg, 
Greece, 

Authorities 
Sweden, 
Cyprus, 
Denmark, 
Czech 
Netherlands, 
Estonia, 
Norway, 
Portugal18  
in 
Bodies 
Czech 
in 
Austria, 
Republic,  in  France,  in 
in 
Sweden, 
Czech 
Republic, 
in  United 
Kingdom,  in  Ireland  and 
in Spain  
Members of BEUC (from 
PT,  DE  and  AT)  and 
Passenger 
European 
Federation 

operating 

Numbers of 
answers 
received by 
Commission 
services 
14 

Numbers of 
answers 
aggregated by 
the associations  

na 

9 

na 

4  

na 

CLIA Europe 
HOTREC - Hospitality 
Europe 
CER - Railways 
Community of European 
Railway and 
Infrastructure companies 

1 
8 

019 

2 
12 

77 

16 Bureau Européen des Unions de Consommateurs. 
17 Awareness of the competent authorities responsible for enforcement of the PTD was raised through message to 
the Consumer Protection Cooperation network.  
18 Spain explained that it did not contribute, as the PTD was not yet transposed in Spain at that time. 
19  A  small  size  German  reseller  of  package  holidays  claimed  being  member  of  CER  and  Airlines  for  Europe; 
CER indicated that the respondent was not one of its member.  

10 

 
 
 
 
 
 
 
 
 
                                                           
ECTAA - The European 
Travel Agents' and Tour 
operators associations 
EHHA - European 
Holiday Home 
Association  
ETTSA - European 
Technology & Travel 
Services Association  

ECSA - European 
Community Shipowners’ 
association 
FITE- International 
Federation of Equestrian 
Tourism 
ETOA - European 
Tourism Association 
aisbl 
Eurogites (European 
Federation of Rural 
Tourism) 
A4E -Airlines for 
Europe’s members 
Others23 

82 

85 

0 

1 

0 

1 

120 

0 

022 

9 

3 

2 

1 

0 

021 

0 

0 

Insurers  

TOTAL 

10525 

19524 answers received 
(105+90) 

18226 of which 
90 answers were 
received directly 
by the 
associations 

Insurance Europe 

6 

627 

20   Also member of ECTAA 
21   ETOA (European tourism  Association aisbl) explained that they did not receive any response or comment. 
ETOA perception is that “the concept, let alone the definition, of an LTA enjoys somewhat limited awareness 
so  caution  may  be  needed  in  interpreting  the  responses  we  do  receive”.  This  was  supported  by  Eurogites 
(European Federation of Rural Tourism). 

22   A small size German reseller of package holidays claimed being member of CER and Airlines for Europe; it 

is however not mentioned in the latter’s list of members; see also footnote 19.  

23   Respondents not being members of an association.  
24   Answers received by Commission services and associations.  
25   Answers  received  by  Commission  services  were  forwarded  to  the  associations  which  the  respondent 
indicated as being a member of. Some answers may have been aggregated by different associations, in case 
of multiple memberships. 

26   Answers forwarded by Commission services and answers received directly by the associations. 
27   6  establishments  operating  in  Austria,  Belgium,  Cyprus,  Czech  Republic,  Denmark,  Finland,  France, 
Germany, Greece, Hungary, Ireland, Italy, Netherlands, Poland, Portugal, Spain, Sweden, United Kingdom 
and Norway. 

11 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                           
Others 

Total:  

Guarantee funds 

EGFATT 

4 

10 

1 

428 

28   EGFATT  aggregated  the  replies  from  four  out  of  its  eight  members  (from  ABTA  Limited  (UK), 
Garantiefonds  Reizen  -  Fonds  de  Garantie  Voyages  –  GFG  (BE/LU),  SGR  (NL)  and  the  Commission  for 
Aviation Regulation (IE)).  

12