Policy & Destination Update, November 2021

Contents include

  • AGM: ETOA in Europe
  • VAT in Germany
  • Health Credentials and borders
  • Destination updates including:
    • Paris LEZ
    • Venice landing contribution
    • Italian ticket and capacity management
    • Italy’s COVID proximity law
    • Amsterdam coach plan and VMR
  • Invitation to attend:

ETOA Year in Review 2021

Access the online version here


ETOA in Europe

At our Annual General Meeting on 28th October, members agreed a constitutional change to transfer legal control of ETOA from the UK to our Belgian entity, European Tourism Association AISBL (ETOA Belgium). Day-to-day, members will notice little difference. ETOA UK will remain the commercial and operational arm of the association. The move consolidates our EU presence, and ensures that we can continue to capitalise on our dual structure. The UK’s role as the EU’s largest source market as well as a valuable inbound market is supported by ETOA’s continued presence and credibility in market. We have appointed a new country representative in Italy, reinforcing our commitment to local presence now in-person interaction is becoming more of an option.

VAT in Germany

ETOA, together with the European Travel Commission (ETC) have written to official in Germany to request they suspend the proposed change to VAT treatment from 1st January 2022. There is a weekly contact group including our partner associations in North America, inbound associations in Germany who agreed text of most recent letter. English version of the content is available here. This change will affect any non-EU based business that sells German product to consumers, and have an impact on the supply chain they work with.

Our latest understanding is that the Ministry of Finance may be open to a further suspension of the proposed change, pending consultation with regional governments. This would be a major success, but still temporary. The goal is to encourage any EU state to take a pragmatic approach until such time as an EU-wide solution is agreed. The early stages of European recovery would be a particularly harmful time to deter non-EU business. Lobbying efforts will continue domestically and internationally.

Health Credentials and Borders

The travel restrictions database on our COVID-19 resources page has been reviewed and the latest version published today. The content covers border entry requirements travelling for tourism and in-destination certification requirements for each EU and EFTA member state and the United Kingdom.

One of the significant changes is France’s new process for converting non-EU certification not connected to EU DCC gateway into a Pass Sanitaire to use in-destination (e.g. US CDC record card). Previously, converting non-EU certification was free of charge and could be done in advance of arrival online. Visitors now have to convert the certifications in-destination at selected pharmacies for a fee of up to €36 per person. This change could have a significant administrational impact on tour operators sending non-EU arrivals to France. We are following the situation closely and are in contact with relevant authorities.

All updates can be found in column D of the database.

Austria – reduction of vaccine validity period for 2 dose and single dose vaccines

Belgium – antigen test now accepted alongside PCR test for border entry (applicable for stays greater than 48 hours)

Czech Republic – Age of children increased from 6 to 12 from when testing requirements become applicable

Denmark – In-destination certification requirements will be re-introduced from 12 November and fully vaccinated from Singapore are no longer be permitted without quarantine following removal from EU white list.

France – new process for converting non-EU certification not connected to EU DCC gateway into a Pass Sanitaire to use in-destination (e.g. US CDC record card). Cost up to €36 per person. Further information also on our COVID-19 resources page.

Hungary – Fully vaccinated from UK no longer require PCR test for entry by air and can attend mass events

Luxembourg – Fully vaccinated from the UK and USA are now permitted

Sweden – Fully vaccinated from the USA are now permitted arriving directly into Sweden

Switzerland – WHO vaccines will be accepted from 30 November to convert into a Swiss Covid Certificate to use in-destination (currently only EMA vaccines accepted).

United Kingdom – WHO vaccines will be accepted from 22 November from approved list of countries, entry in England, Wales and Northern Ireland (Scotland to be confirmed).

Columns P and Q have been updated to outline current requirements for UK and USA nationals fully vaccinated. This takes into account the UK connecting to the EU DCC gateway. Please note that the USA is not currently connected to the EU DCC gateway but some EU states are accepting US vaccine certification on the same basis as countries connected to the EU DCC gateway.

Climate Action

ETOA was a supporting signatory and launch partner of The Glasgow Declaration ahead of COP26. To become a signatory, please click here. You can read more about climate emergency and tourism here.



Paris LEZ

The proposed plan for Paris’ Low Emission Zone in the city center is still on track for summer 2022. There have been objections about the plan from coach companies amongst others as the plan would limit coach access, except for hotel guests. We are following the development of the plan and are in close contact with the city. The plan resemble the coach access plans in Madrid and Rome. More information about the proposed plan here.


ETOA has appointed Danja Nebuloni as our new country representative in Italy, reinforcing our commitment to local presence now in-person interaction is becoming more of an option. Danja will work closely with our Italian members and as our in-destination expert she will support international and local members navigating the business environment.

Venice landing contribution

As mentioned in previous updates, our understanding is still that the fee will not be imposed from 1 January 2022 but is delayed until summer 2022. The official website is not updated with a new date. We are in dialogue with the Venetian authorities and will keep members updated via our tourism tax page and our updates. We have been informed that the collection of the fee is supposed to be via the Venezia Unica platform.

Museums and attractions – ticket and capacity management

Group bookings continue to frustrate members due to lack of consistency and transparency. Maximum group numbers seem to range from 5-50 per group. Some require local guides to accompany small groups, which increases cost and operational complications due to a lack of available local guides. We continue our dialogue with Parco archeologico del Colosseo through video and in-person meetings to improve booking and refund conditions for members. If you experience issues with any particular museum or attraction, please contact policy@etoa.org.

COVID proximity law and coach groups

It has come to our attention that Italy’s COVID proximity law is proving to be complicated for coach tour operators as single positive cases in a group may lead to the entire group forced to self-isolate for 7 days depending on interpretation of the rule. The rule means that ‘high risk’ contacts to COVID positive cases must self-isolate. A high risk contact “is defined as “a person who has traveled seated by train, plane or other means of transport within two places in any direction of a COVID-19 case; the travel companions and the staff assigned to the section of the plane / train where the index case was sitting are also close contacts”. (Auto translated from Italian). Interpretation and enforcement of the rule is ambiguous and sporadic and the continuously changing regulations are making planning complicated. More information about the proximity law here.

We are in contact with relevant authorities and our lawyer to understand implications. If you have evolved a company policy around this particular issue, please share this in confidence with policy@etoa.org as we are gathering examples of good practice.


Amsterdam entertainment tax (VMR)

While authorities in Amsterdam have been approaching local operators and sightseeing companies to declare numbers for VMR, it has come to our attention that some international operators are also being approached, regardless if the company is liable or not. It’s important to note that this fee is only applicable to guided tours (land or water) and not on transfers. Liability to declare numbers and pay the tax lies on the company providing the “entertainment”. More information on our Tourism tax page. If your company has been approached and you are unsure of next steps, please contact policy@etoa.org.

Amsterdam coach plan

Access to affected hotels within the S.100 must be by smaller vehicles, or boat. We understand that access to cultural attractions will be permitted for groups of children (up to 12 years old) and those for whom a 300m walk is problematic. A new system of drop-off pick-up points is planned, but practical obstacles remain: residents may oppose construction of additional parking places in the intended locations; safe ways of providing drivers access to real-time availability must be devised. During 2022, construction of a larger coach park to the east of Central Station at Ruijterkade Oost will continue. Inter-modal transfer between river boats and canal boats will be possible.

ETOA’s recent paper on the plans is available here.

Upcoming Events & Meetings


ETOA Member Drop-In: 23 November 

Members are encouraged to share this opportunity with colleagues to help raise awareness of ETOA services,​​ meet some of the team and fellow members and discuss issues affecting your business. Register here.


Relaunch’22: 30 November

Registration for Relaunch’22 closes tomorrow. This is our next online round-the-world B2B workshop.  Relaunch’22 will provide unparalleled access to networking opportunities to travel suppliers and buyers of European tourism services. Qualified buyers are joining from global markets: ​​Europe, North America, Asia, South America, Australia, Africa. Over 300 companies already registered, check the live attendee lists here.


ETOA Group tourism working group: 1 December

We will hold our next group tourism working group meeting on 1 December, online.

The meeting is a round-table meeting exclusively for ETOA’s tour operator members. The purpose of the meeting is to discuss operational, contractual and productional challenges in European group tourism with peers and experts.

Attendance might particularly be of interest to Operations, Contract and Product Managers. The meetings are confidential and collegial, ensuring openness and candour. During these member-led meetings we discuss and clarify challenges related to:

  • Ticketing and capacity management
  • Contracting
  • Coach access
  • Tourism tax
  • Guiding
  • Visa and border crossing

Register here

Partner events

Visit Paris Region North America Workshop: 16 November 2021

ETOA has partnered with the Paris Region Tourist Board to host their online workshop targeted at the outbound leisure market from North America. Read more here.

Find out more about our future and previous partner events here.

Insight Hub

Check our latest statistics, opinion and research pieces on the Insight Hub.

Tour Operator Support for ETOA during 2021

The last 18 months have tested the industry as never before. ETOA’s own team reduced in size and focused its efforts to support its members through action and information: we continue to handle a wide variety of queries, especially about travel restrictions. As well as our supplier members, we are very grateful to operators who have supported us financially during 2021. Voluntary contributions are still welcome. If you wish, please click here to log-on to your account and select the voluntary contribution link at top of the page. Thank you.

Member information with ETOA

If you have not done so already, please review your company information via this link. To see whom ETOA currently holds as the ‘main contact’ check your listing via this link (you will need to be logged in to see all the information).

Meanwhile, please continue to send any comments you may have about the website to: policy@etoa.org

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