domestic packages to customers. This issue would not arise in the context of the EU’s reforms as it would undermine the whole purpose of EU directives and the integrity of the internal market. Such considerations do not appear to trouble the UK government, no doubt due to the history of devolved government and the age-old distinction between the three jurisdictions making up the UK (England & Wales, Scotland and Northern Ireland). While the UK government’s consultation proposes that consumers may benefit from increased choice because of reduced regulatory burdens, consumers would lose the extra protections provided by the package travel regulations and be forced to rely on general consumer law protections if the scope were narrowed to overseas package holidays only. The proposal to remove some UK-only domestic package holidays from the protections offered by the package travel regulations notably gives rise to the following concerns: • Research published in November 2024 by the UK DBT and conducted on its behalf by Verian has shown that consumers are prepared to pay a premium for package holidays due to the protections provided by the package travel regulations2, including an additional premium of £106 for a domestic package holiday. Removing domestic package holidays from the scope of these protections would disadvantage consumers, reduce choice, increase costs and remove insolvency protections and protections that ensure the proper performance of travel services. • The creation of two separate regimes for domestic and international travel may result in increased confusion for consumers. UK-only package holidays can be equally and sometimes more expensive than international travel, with similar issues arising if things go wrong. There is a strong argument, therefore, that they should not be subject to different regulations or responsibilities on the part of the package organiser. • Removing some UK-only domestic package holidays would disproportionately affect certain sections of society, including those with lower incomes, senior citizens and those with disabilities who may need or want to avoid international travel3. Legislative reform should ensure 2 https://assets.publishing.service.gov.uk/media/67e69c1337baea91c58c9ffa/Package_Travel_-_Updating_ the_Framework_-_Consumer_Research_Report.pdf 3 Research conducted by the UK’s DFT in 2024 showed that people with some health problems or disabilities are more likely to choose to holiday in the UK, either through a package holiday or an LTA, but are less likely to travel overall: Research into the Package Travel and Linked Travel Arrangements Regulations 2018 (PTRs) – a discrete choice experiment, Table 9, p.25 4 CHRISTOPHER DEACON
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