City tourism: Operators Update

July 2018

Croatia Further to previous news that Croatia has imposed stricter controls on guiding in certain sites, ETOA received an initial response from the Ministry of Tourism explaining the status quo, including details of possible fines. The letter may be seen here. This initial response is confined to legal explanation, and includes the assertion that one of the criteria for the new restrictions was consumer protection. We note that the Ministry is reviewing the situation and we will continue to make the point, in relation to protection of consumer interests, that operators’ clients’ interests
are harmed by unduly restricting non-Croatian tour guides’ market access.

Switzerland Further to previous interim update in May, we have received unofficial reassurance as follows: “…while it has been admitted that the revision [to VAT registration requirements] never was intended for the international travel trade, our legislation is very complicated and it will take time to change anything.” While we do not yet have any formal assurance, it now seems much more likely than not that the position in effect until end 2017 has not changed; operators based outside Switzerland will not be obliged to register for Swiss VAT, irrespective of turnover.

Attractions Thank you to those who expressed interest in joining ETOA’s activity on this topic. We will be in touch soon with next steps. Recent meetings at both the Alhambra and Eiffel Tower have highlighted some of the key issues: desirability for transparency of allocation in capacity management; the nature of the secondary sales market; the implications on value-adding intermediation of attractions privileging direct sales; advance information for operators’ programme planning process; the need for product diversification.

Product Development ETOA has been in dialogue with the Council of Europe (CoE) for some years, most recently running an operators workshop at their event in Lucca in 2017. Members’ attention is drawn to CoE online resources, some of which are adaptable to trade use, and may assist in product development.

City Updates



We are planning a seminar in Barcelona in late November, together with the city, whose focus will be attraction ticketing and capacity management. If you have any comment on local attractions and related booking and ticketing processes, please email Joanne Cadier.



ETOA attended a meeting on 28th June: it was lengthy and, while it did not yield concrete results, there were encouraging signs. The system of nominative ticketing will remain. Details of ticket allocation from 2015-2018 were provided, and a commitment to increased transparency was made; relevant information will be publicly available. The “Monitoring Table” was convened by the Board of the Alhambra and Generalife at the formal request of the City of Granada. The agenda included the development of the system of reservations and ticket sales via the Authorized Agents channel during 2018, as well as the modifications and changes made in order to improve the quota procedure related to groups. Those present included the Councillor for Tourism of the City of Granada, the representatives of all political parties represented in the City Council, and the President of the Board of the Alhambra. A brief summary of the situation was given, and subsequent debate focused on the need to eradicate the illegal resale of tickets. Further action is expected. We will provide further information about ticket allocation and any other developments.


City Access – 18th September
Each year the Paris city council closes Paris to all traffic. This year, 18th September will be ‘Paris Car Free Day’ from 11am to 6pm. No cars or coaches may drive in the centre of Paris during that time. More information available via the following link.

Eiffel Tower

Ticketing – Online sales for August should be open on 28th June. The group counter which closed on 1st June is closed definitively and will not reopen. In principle this means 50% more tickets should be available online. If operators do not have a reservation purchased online in advance, tickets for the same day may only be obtained by lining up in the public queue. Tickets will be sold for immediate use only; for groups, everyone must be present at time of sale. It is no longer possible to purchase separate tickets for lifts from the 2nd to 3rd floor. School groups must apply direct and not through an operator or 3rd party agency, see note on meeting below.

Access restrictions and development in the vicinity – From early September (currently scheduled 1.9.18 but subject to change) the north pillar will be closed for renovation works to a lift that was first commissioned in 1965; works are provisionally expected to last 30 months. The Eiffel Tower will be closed from the 13th July from 11pm and will reopen on the morning of 15th July. This will be the last occasion for a few years that the tower will be used as a platform for Bastille Day fireworks. The glass wall being constructed around the tower is forecast to be completed towards the end of July. The works that are being carried out to the surrounding areas and up to Trocadéro will take a few years to complete, as previously indicated.

Summary of ETOA’s meeting with SETE (Société d’Exploitation de la Tour Eiffel) on 26th June
Direct sales are SETE’s strategic priority. Online sales have just overtaken salesin-person. SETE’s explicit long-term intention is to promote direct sales. Given very strong demand and strictly limited capacity, their expectation is that B2C sales will represent the clear majority of total sales, perhaps 80% of the total within a few years. Their intention is that B2B sales should entail clear value-adding for the visitor and not simple resale. All B2B groups must be accompanied.
Pricing and capacity management. SETE may not alter ticket prices in response to demand; any changes must be voted by the Conseil de Paris (it is not currently legal to charge visitors more than locals; maintaining affordability for domestic visitors is a priority). SETE intend to manage volume according to client type: B2B and B2C, privileging direct sales, as above. The quota of tickets available for each client type is currently undisclosed, though it is expected that the tickets available to the c.10 grandes comptes may become limited to c.15% of the total stock. Restrictions for grandes comptes status are impractical for most: commitments for low-season volume (excluding Christmas period) and strict no-show limits are hard to fulfil for most operators. It is a reasonable inference that the scheme is not one that SETE seeks to expand.

B2B sales outside the grandes comptes scheme will continue ad hoc with availability from 90 days prior to date of visit. That availability is subject to yield management in the sense that SETE may reallocate stock between B2C and B2B and choose to keep some in reserve. B2C bookings are available online from 60 days prior to visit should operators wish to inform clients for their free-time planning purposes. Maximum number of visitors per booking for B2C bookings is 9; checks are made to detect if the same card number or cardholder name is being used for multiple B2C bookings.
Eiffel Tower capacity fluctuates between c.6 – 7 million per year depending on lift availability and average duration of visit since visitors are only admitted as the legal capacity limits permit. If earlier visitors are spending longer than normal, this will have a knock-on effect. Capacity cannot be increased since the passenger lifts may only be operated 15 hours in 24.

Discounted rates for students. B2B stock may be used for direct sales to schools at discounted rates. Tarifs scolaires are not available to any for-profit organisation. Schools wishing a group reservation must apply directly, not through an operator or other 3rd party agency. The school must provide their official registration code and a formal letter stating the number of students. In theory, the visits must take place during normal school time, though this requirement seems to disregard the practice in many countries of school trips taking place during holidays.

Request for EU VAT number in order to make B2B purchases. Further to recent reports, SETE maintain that it is a legal necessity for B2B clients to supply an EU VAT number, such as is required for intra-community sales (i.e. sales between entities in different EU member states). SETE do not have any duty to investigate whether the number itself is valid. In practice, this means that non-EU operators without a branch, partner or subsidiary registered in the EU must secure tickets through an EU-based intermediary. ETOA is querying the legal coherence of this position: if the Eiffel Tower may not sell services to a B2B client that lacks an EU VAT number, then a French DMC (for example) could not sell services to the same B2B client; non-EU entities would be unable to buy travel services in France on a B2B basis. ETOA will continue to address this unwelcome and unnecessary barrier to trade.

Paris Tourist Office Changes as of 29th June 2018

The Tourist office located at 25 rue des Pyramides is now closed. Visitors may use the tourist office located at 29 Rue de Rivoli, 75004 Paris, nearest metro Hotel de Ville. Opening hours: daily from 9am to 7pm from the 2nd May to 31st October; and from 10am to 7pm from the 1st November to 30th April. Please note it is closed on 1st May.

There is also a tourist office located in Gare du Nord, opposite tracks 7-9 in the main hall. Opening hours: daily from 8.30am – 6.30pm. Closed 1st May, 25th
December & 1st January. The Tourist Office Administration team has moved to 144 Boulevard Macdonald. 75019 Paris.

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