Policy Update, April 2021

European Policy

Health credentials and Borders

ETOA’s current understanding is that the likely publication date of legislation enabling the EU’s Digital Green Certificate (DGC) will be in late June. Meanwhile, although a coordinated approach would be easier to manage, a fragmented re-opening is already in progress and is likely to develop. Croatia has opened subject to conditions, and Greece seems likely to next month.

As an illustration of the challenges to fast-track implementation, the European Data Protection Board issued an opinion which asked for technical amendments to the legislative proposal for the DGC. All amendments are subject to debate and challenge. More information here.

What difference will the DGC make?

Possession of a DGC showing appropriate test results will not confer a right to travel. EU member states will retain discretion at borders as regards immigration. A sense of the political challenges for the Commission and the EU generally can be gained from a statement made by Commissioner Reynders to committee at the European Parliament this week.

“We want to ensure that all citizens receive the same treatment when Member States decide to lift restrictions of free movement to holders of vaccines, test, or recovery certificates. The proposal aims to put in place certificates that contain the same data which are secure, and which can be accepted by all Member States. The proposal has nothing to do with internal border controls. On the contrary, our intention is to facilitate the easing of the current restrictions to allow safe free movement until the end of the pandemic. We regret that some Member States have reintroduced border controls to check whether travellers comply with the public health measures. We do not see the proposed certificate as a reason legitimising such border controls. The decision to reintroduce checks at internal border falls under the responsibility of the Member States, and such a measure should only be taken as a measure of last resort. We want to provide a tool that national authorities can rely on to facilitate free movement. Similarly, an airline can be asked to verify the validity of the certificate in a simple way at the check in. We want to help citizens and airline staff by giving them a certificate that is understandable and reliable. Long discussions at the gate should be avoided”.

For more detail about legislative state-of-play in the EU on DGC, the current mandate agreed by the Council (Member States) for negotiation with the Parliament is available here.

Restoring international mobility

For long-haul markets, the risk of lost business to Europe is becoming more acute each day. For ETOA’s recent webinar on the topic, Re-Opening Europe: Follow the Evidence please click here. Our statement on the topic is here.

In parallel to EU-related efforts, we have been feeding into UK discussion, pushing for wider acceptance of antigen tests and importance of a co-ordinated approach among the nations of the UK to help restore travel from and to the UK. We also contributed to the OECD’s Blueprint for International Mobility, whose current version is available here. This initiative is intended to encourage convergence among international protocols.

Flight routing and tests for transit passengers

Due to limited direct flight capacity from long-haul source markets to some destinations, whether non-European visitors can easily get to newly open destinations is in question. We are seeking clarification about the eligibility to board flights originating outside Europe destined for ‘open’ countries routing via airports in a ‘closed’ country if luggage is checked through and immigration does not take place until final destination. We have heard reports of PCR requirements for transit passengers.

Our current understanding is that entry requirement of final destination countries will be the governing factor providing they are not in Schengen (such as Croatia). But if final destination is within Schengen, and connecting hub is in Schengen, any connecting flight will be intra-Schengen. Thus, the pre-boarding requirements for a flight to Greece from the US via Germany are likely to be subject to conditions in addition to those imposed by Greece. It is reported Germany has introduced PCR testing requirement for transit passengers: we are seeking confirmation. Meanwhile, members are advised to consult their airline partners.

Information resources on border restrictions 

Planning continues to be very difficult due to lack of co-ordination between countries on border controls and pre-conditions, especially with regards to transiting. While the following resources list controls and conditions currently in force, they may still assist in planning:

  • Re-Open EU (recently updated with a travel planner taking into account origin market).
  • IATA (detailed entry requirements)
  • Sherpa (colour coded map to reflect border controls from a specific origin market)

These resources are listed on our Coronavirus resources page, alongside national government webpages. Please continue to contact us with any questions at policy@etoa.org

UK and Ireland

The United Kingdom government published their framework last week on restarting international travel for tourism purposes departing from and arriving in England. The earliest date for outbound travel for tourism is 17th May, from when the UK government’s traffic light system will be launched for arrivals into England. Travel from within the Common Travel Area to England (where the traveller has stayed for 10 days) is excluded from these measures. We await further details to be announced by early May on initial country allocation and whether fully vaccinated travellers will be exempt from testing requirements (our current presumption is that they will not be exempt).

We await announcements from the devolved administrations of Northern Ireland, Scotland and Wales as to whether they will align with the UK government’s timeframe allowing direct international travel, and its traffic light system. Please note that the EU and UK Government’s traffic light systems may not be directly comparable in methodology or classification.

The Irish government has added additional countries where travellers from today are now subject to managed hotel quarantine on arrival into Republic of Ireland. While fully vaccinated travellers are currently not exempt, we understand this is under review. Latest understanding is hospitality is not expected to re-open until June at the earliest with an update due in May. Timeframe for hospitality re-opening in Northern Ireland this summer has yet to be announced.

Visa policy: e-visas

ETOA has been working with Commission consultants on options for digital visas, and a streamlined digitalised process which will minimise the need for applicants to present in person. If you wish to add your perspectives, please find the EC consultation via 11th March update on our Visas and Borders page.


Our current understanding of EU countries’ intentions to require non-EU buyers to register for VAT in destinations where they buy services is given on our TOMS page. Germany’s decision to suspend its proposed change of treatment for the rest of 2021 represents a best case lobbying outcome in current circumstances, but the ambition is that all EU states should delay any major changes until a review of TOMS is complete.


The European Parliament will meet on 26th April to vote on ratifying the EU-UK Trade and Cooperation Agreement. For guidance as to some of the implications of this agreement please see  our Brexit Post-Transition and the member-only guiding regulation page.

ETOA Tour guide ID Card (TGID)

Our systems updates have proved more problematic than we had hoped: we apologise for the delay in opening the application system. We are conducting final testing and, as soon as the system is open, we will announce on this page and provide any further information required.


While testing capacity and acceptance of antigen tests grows, costs and logistics are still prohibitive for many. Destinations have made safe travel a priority as they prepare for re-opening, but widespread availability of testing prior to visitors’ return home is still limited: it represents a competitive opportunity for destinations willing to invest. Risk of quarantine or self-isolation requirements post-holiday remain a major deterrent.

France was the subject of a webinar this week focusing on the funding mechanisms for EU recovery, the role DMOs play, and scope for enhanced public-private collaboration. For more information and recording (in French) click here.

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