ETOA Policy Update | February 2022

Welcome to a new-look ETOA Policy Update, which will appear three times a year, giving an overview of ETOA policy news and activity​​​​. This edition features:

  • Travel requirements
  • Tourism and Tax
  • Supporting Exports
  • Collective Redress
  • Climate Action
  • Product diversification and market developments
  • Cruise tourism and sustainability
  • Industry partners
  • Industry Insights
  • ETOA Calendar

European Policy

Travel requirements

Europe is reopening. The requirement for fully vaccinated travellers to take tests is reducing, as is the need to present certification in destination. The focus is shifting from the complexity of restrictions to the nature of a long-term enabling framework to assure freedom of movement at borders and in destination. Such a framework will be necessary whenever circumstances require a reintroduction of public health measures and verification of individuals’ status.

An EU policy success has been the development of its digital covid certificate, EU DCC, whose framework currently includes 62 countries (27 EU and 35 Non-EU), with more pending. Originally intended as a temporary measure, the enabling legislation must soon be renewed. That does not mean a requirement to present health credentials should continue any longer than necessary, but it increases the likelihood that the EU’s scheme becomes the reference standard others adopt.

For long-haul markets, the European Council’s recent revised recommendation that member states should accept non-EU travellers with WHO approved vaccines is welcome. Currently, while most EU/EFTA member states no longer require testing for fully vaccinated travellers, the definition of ‘fully vaccinated’ and acceptance of WHO approved vaccines not yet approved by the EMA is still subject to national variation, as are rules for children and the acceptance in destination of certification deemed sufficient to cross borders.

As cross-border product is among Europe’s most popular offer in its valuable long-haul markets, the practical consequences of fragmentation remain severe: multi-country holidays entail multiple passenger locator forms (PLFs) and other forms of self-declarations. The EU’s standard PLF has not been widely adopted, and this appears unlikely to change now that national systems are firmly embedded. Visitors from countries whose health credentials are not within the EU DCC framework have additional obstacles.

For our current database of links to government resources for prevailing travel requirements, please click here. It includes an overview of prevailing requirements for fully vaccinated visitors and lists the PLF(s) and other forms that may be required for each country.

Travel requirements

Click here for latest updates

Tourism and Tax

The EU is developing policy proposals to replace the current tour operators margin (TOMS) scheme, whereby EU operators and agents avoid the need to register in all the various countries in which they deliver product, and destinations retain the VAT charged by services enjoyed there. At issue is how to evolve a regime which rewards value-adding in both the EU and its source markets, keeping administrative burdens low and ensuring an equitable distribution of economic benefit.

Risks are clear. Germany’s proposal to require non-EU entities to register for VAT, and to collect VAT on the retail price of holidays in Germany sold to consumers anywhere in the world was thankfully suspended for a second time, not least due to pressure from regional governments and industry groups but is widely expected to be implemented from 1st January 2023. That this would damage the German inbound industry seems curiously secondary to regulatory dogma. Tourism’s ecosystem is unlike any other and needs a regulatory framework and long-term strategy to match.

Supporting Exports

At the heart of Europe’s competitiveness is its export economy. However, due to the way industries are classified by statisticians and tourism’s cross-cutting nature, a recent report EU exports to the world: effects on employment does not identify tourism as one of Europe’s most important exports.

Partly, the problem is one of perception: how can a holiday enjoyed in Europe be an export? But, if it is sold to a business or consumer outside the EU, indeed it is. ​​​​​The business of packaging product, which takes place both in the EU and its source markets, is an essential part of the value-adding which ultimately benefits the European supply chain.

ETOA and its partners will continue to work hard to promote the value of tourism exports – to businesses across Europe who need long-haul demand to complement intra-European and domestic clients, as well as policy makers trying to design a framework well-adapted to Europe’s long-term interests.

Risky Business – Collective Redress and the Tourism industry

Collective redress, or representative action, is the subject of the EU’s representative action directive. This must be transposed by member states before the end of 2022 and will be in force mid-2023. Given the high degree of consumer protection in tourism, with its established and largely effective methods of redress that minimise the need for litigation, this is undesirable and unnecessary. The need to adapt the regulatory framework to suit a changing marketplace is clear but encouraging the development of a speculative claims handling industry could well prove counter-productive. To learn more, please register for this expert webinar on 23rd March at 11h00 CET organised by ECTAA and ETOA.


Climate action

ETOA has published its climate action plan. As we are a trade association that also offers products and services, it is a hybrid plan for our public policy role as well as our commercial activity. We encourage all tourism stakeholders to sign the Glasgow Declaration (we were a launch partner and supporting signatory) and adopt its framework in a way that suits them.

Product diversification and market developments

In our recent webinar on southern Europe product demand and development, featuring experts from USA, Italy, Greece and Spain, the panel discussed whether product with sustainability metrics (such as verified carbon footprint and positive community impact statements) might attract a premium price.

The market for product that aligns with business and consumers’ own sustainability goals is growing. Coupled with increased interest in product that combines well-known destinations with less well-known but high-quality elements, this is positive news for smaller suppliers, lesser-known attractions and destinations seeking to disperse visitor flow.

Cruise tourism and sustainability

Registrations are still open for an event in Brussels and online on 1st March focusing on cruise tourism: Pan-European Cruise Dialogue, hosted by the European Commission. ETOA will be moderating a destination-focused panel and is a member of the external peer review group for a charter for sustainable cruise tourism, currently under development.

Submissions for examples of good practice are still sought by the consultants working on the report: there is a lively debate as to what criteria should be used to assess merit. To contribute examples of good practice, please click here.

For more information about ETOA’s policy activity, please contact us.

Industry Partner News

ETOA partners with a range of organisations: we have much in common with stakeholders across the industry from destinations to research specialists, regional networks to sustainability consultants.

We are delighted to announce a new partnership with ForwardKeys, whose innovative research provides clear insight into patterns of recovery and demand. We will be featuring their material at our events and online.

To sign up to the ForwardKeys newsletter, please click here.

If you would like to know more about ETOA industry partnerships, please contact us.

Catch up on useful Insights

We have recently updated our Insight Hub with new research pieces. This month there are entries from our partners at the European Travel Commission on long haul travel sentiment, domestic and intra-European travel, and trends and prospects for 2022. You can also find the latest research from Expedia in their Travel Recovery Report and Traveller Value Index, as well as the most recent hotel webinar from STR.

It is encouraging to see in these reports that European travel sentiment is positive in the American and Asian markets, and that travel-related searches online increased by 70% in 2021 compared with 2020. Domestic travel is expected to exceed pre-pandemic levels in 2022, with international tourism expected to return to those levels in 2024.

ETOA Year in Review 2021

Access the online version here