Package Travel Regulation implementation guidance

The Travel Package Regulation (PTR) 2018 came into force in the UK in July 2018.  The new regulations will result  in many more established business practices and businesses models being regarded as package travel and therefore subject to the full requirements of the travel package directive.  The regulation also creates a new type of package the linked package arrangement (LTA) which will bring even more product under the auspices of the PTR, albeit with less onerous requirements attached for businesses, than for a full formal package arrangement.

The Tourism Alliance has produced a guidance note for smaller tourism businesses:

PTR 2018 Tourism Alliance Guidance

This supplements the Department for Business Energy & Industry Strategy’s own guidance for business which attempts to covers all aspects of the regulations:

PTR BEIS Package Travel Guidance

and both references the draft statutory instrument that brought the PTR into UK law on 1 July 2018:

PTR 2018 Statutory Instrument

As at 18 July points to note:

There is 6 month review programmed and already some thought of trying to remove the apparent inclusion of two elements provided by the same business, i.e. a hotel offering accommodation and a pre-booked and paid for spar treatment.

The regulation and its interpretation contains many grey areas and is conditional on often precis circumstance.  More clarity and clarification is required.

BEIS have apparently issued instruction to Trading Standards officers who will enforces the regulation that this should be applied with a light touch, they have also indicated that  the regulation is not intended to impact on small business.  Initially at least small business shouldn’t be over alarmed or take dramatic action to change working practice until such times as the requirements are clearer.

We are in discussion with the insurance industry in order to identify whether very low cost insurance based coverage might be available to mitigate the more onerous requirements of PTR for small accommodation and potentially other effected businesses (largely insolvency insurance requirements).  This is likely to be predicated on high volume take up and would therefore require the assistance of destinations to help promote the product(s) to their local businesses.   If you are interested in this approach please let us know.  Understanding the appetite and scale of the potential market for the product is a perquisite for negotiating an attractively low premium.