PTD – Uk Implementation. Coming soon?

EU member states are expected to have implemented the PTD (Package Travel Directive EU 2015/2302) by 1st January 2017.

There is no getting away from that. And yet, here we are, in mid June 2017, with not even the proverbial sausage in terms of a PTD consultation even.

When will we get the final, UK wording? It is one of the most frequently asked questions here a Travlaw. Frustratingly, we have been giving the same answer for some time now. “Anytime now. Anytime...”. See our previous posts on this.

It is entirely fair to say that the UK Government has had plenty of other things going on in recent times. Brexit, general elections, terror attacks, more general elections and so on. It’s also fair to say that other industries are also complaining of key issues for their way of life not being addressed. However, our concern is squarely with the UK travel industry, and this is a vital corner-piece , whether inbound or outbound. It is very, very easy to empathise with the frustration of our many clients who want to crack on with planning.

Is Anyone Else Ahead of The Game?

Of course, the other EU member states have an equal obligation to implement the Directive into their own national laws, and it seems there is a general mix in terms of who has already and who hasn’t. It has been widely reported that Germany has passed their own version, so clearly they are ahead of the game. Or are they?

Taking a step back, for years now the great and the good of the Travel Industry here in the UK have been largely (largely) comfortable with what a “new” package is. However, the introduced concept of a “Linked Travel Arrangement” (LTA) has baffled all, and no one we have spoken to has found a use for it at all. Or even been able to say what it might be used for.

Germany’s creation of the Combined Travel Package is a curious one. It certainly seems to strike a middle ground between a package and and LTA, but suffers from the same criticisms that similar ideas thrown up here in the UK have seen – it simply may not work.

Our analysis is that it is a good effort, but would indeed (as we read it here) fall foul of a strict reading of the Directive.

Of course, Germany have at least consulted and implemented on the Directive, to fair play to them. All eyes this side of the Channel now turn to the BEIS. Anytime now. Any time…

Matt Gatenby, Travlaw LLP

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