German travel and tourism associations have criticized the planned revision of the EU Package Travel Directive, warning of risks to competition and the broader travel economy. The joint statement comes ahead of the trilogue negotiations between the European Commission, Council, and Parliament, which begin on 24 September. The associations argue that the proposed changes would weaken package travel as a product and impose disproportionate burdens on travel organizers.
The associations involved include ASR, BT4Europe, BTW, DRV, DTV, Forum anders reisen, IHA, RDA, VDR, and VIR. They presented a united position paper urging both the German government and EU lawmakers to make corrections during the legislative process. According to the groups, protecting the strength of package travel is essential for travelers and businesses alike.
Concerns Over Package Travel Definition
The associations criticized the current proposal for failing to clearly define package travel. They argued that travel intermediaries should remain able to combine multiple individual services without automatically assuming the full liability of a tour operator. The associations supported the Council’s suggestion to reintroduce a clear distinction between package travel and individual services.
They also called for business travel to be excluded from the directive when based on framework agreements between companies and providers. Such trips, they argued, do not fall under consumer protection rules and should not create additional regulatory burdens for travel agencies and organizers. A full exclusion would prevent disproportionate costs for the sector.
Disputes Over Cancellation Rules
The groups strongly objected to the criteria for “unavoidable and extraordinary circumstances” that allow travelers to cancel free of charge. They argued that the EU Parliament’s proposal to expand these criteria to include residence, place of departure, and destination was impractical. Instead, they said the decisive factor should remain the assessment of the German Foreign Office, whose travel advisories and warnings already serve as a legal basis for such circumstances.
The associations also criticized the proposed 28-day rule that would allow free cancellations up to four weeks before departure in extraordinary circumstances. They argued this measure unfairly shifts general life risks onto organizers, leading to financial strain on businesses. They called for a fairer distribution of risks between travelers and travel companies.
Implementation Timeline and Economic Impact
The associations stressed that the travel industry operates on a business year different from the calendar year. They requested that any new directive take effect on 1 November or, alternatively, 1 January, to provide sufficient planning security. Implementing new rules at other times of the year would disrupt booking cycles and business operations.
Germany is the largest package travel market in Europe, accounting for 41 percent of all EU package trips. Within Germany, nearly one in three vacation trips is booked as a package holiday. The sector is largely composed of medium-sized enterprises, which the associations said would be most affected by overregulation.
“Our goal must be to strengthen package travel as a proven and safe product – not to weaken it. Otherwise, the victims would not only be the organizers but above all the travelers themselves,” said the associations in their joint statement. They pledged to continue pressing for necessary changes in Brussels and Berlin.
The groups warned that excessive regulation could undermine the backbone of the German travel economy. “Overregulation would endanger the backbone of the German travel industry – with serious consequences for companies, employees, and millions of travelers,” the associations stated. They called on the German government to represent national interests firmly during trilogue negotiations.
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