ETTSA Issues
Fragmentation of the offering and its effect on price transparency
Airlines often add surcharges during the booking process on their own website as part of an increased trend of unbundling. This means that the ultimate amount charged to the consumer is significantly higher than the advertised fare. While independent distributors, including ETTSA's members, only advertise fares that include all surcharges, the lack of transparency on the part of such airlines misleads consumers, prevents them from comparing prices, and thus creates competitive distortion.
EU Fitness Check of Air Transport Legislation
The European Commission is currently reviewing a number of pieces of legislation governing the air transport industry, to check if they are fit for purpose. They include the Code of Conduct for Computerised Reservation Systems, and the Regulation on common rules for the operation of air services in the EU (Reg. 1008/2008) which contains provisions for transparency of air fares and ancillary fees. ETTSA is working with the Commission to provide the indepedent travel distribution industry perspective.
EU investigations of airline alliances and consolidation
With EU regulators applying increased scrutiny to airline alliances and consolidation, it is important that they start looking at the impact alliances, and other forms of airline consolidation, have on distribution. Alliances and airline groups will become more powerful sales and marketing entities in the future, which means that they will have a tighter grip on the entire value chain and much more dominant positions than their individual airline members. There is a risk that this may have adverse effects on fares, and on the end consumer.
EU regime on Air Passenger Rights and Insolvency Protection
We welcome the comprehensive Air Passenger Rights regime in force in the European Union. However, ETTSA calls for a level playing field in terms of passenger protection, and encourages the European Commission to look at better protecting travellers from airline insolvency. We are working with the European Commission and the European Parliament during its ongoing review of the Air Passenger Rights Regulation.
Revision of the EU's Package Travel Directive
As the European Commission is revising its aged package travel rules, it must look at the disparity between the high levels of protection offered to buyers of travel packages and the almost non-existent consumer protection in case of airline bankruptcy. With airline failure being a significantly higher risk than travel agent failure these days, it is in the interest of consumers that EU protection rules should be the same across the board, regardless of who is the distributor of a travel product.
Implementation of the EU Consumer Rights Directive
Thoroughly enforced consumer rights are an important tool to achieve an effective online internal market, and a competitive and customer-friendly travel industry. However, in order to safeguard the competitiveness of online travel businesses, consumer rights must be transposed, implemented and enforced in a harmonised way across the European Union.
VAT treatment of hotel reservation services
With the implementation of VAT rules for hotel reservation services in the process of being finalised, it is important that Member States agree on a harmonised application of these rules across the EU. Our industry operates in multiple countries and levying VAT where the immoveable property is located creates substantial complications in terms of compliance, while not providing national governments with any additional VAT revenues.
Liberalisation of Europe's cross-border rail system
It is our view that a competitive European rail system would benefit greatly from embracing the independent distribution channel and taking advantage of its global reach. ETTSA and its members are working with policy makers and the European rail sector to facilitate rail integration into independent travel distribution and thus help strengthen the competitive position of rail in Europe. This will yield significant environmental, commercial and consumer benefits.