In the digital sphere, when reputational systems or AI-based recommendation tools are deployed, transparency duties under the DSA and, where appropriate, the AI Act may also apply. IX. A ROADMAP FOR EUROPEAN‑LEVEL SOFT HARMONIZATION Given the diversity of culinary traditions and the distribution of administrative competences within the Union, a single EU-wide system for restaurant classification would be neither desirable nor easily defensible. The more realistic and legally coherent approach lies in a form of soft harmonisation built around a set of guiding principles. First, quality schemes should remain voluntary but should rest on clear and auditable criteria that are publicly accessible and open to verification. Second, interoperability should be promoted through the use of recognised standards, consistent with Regulation (EU) No 1025/2012, and through transparent data practices that enable cross-border circulation of information. Third, compliance should be conceived ex ante, aligning with the requirements of the Services Directive, food law and consumer protection. Finally, digital governance must comply with the obligations established under the GDPR and the DSA, while aligning with the risk-based framework now set in the AI Act. For Member States such as Portugal, Spain and France, these principles translate into practical measures: publishing machine-readable versions of classification criteria and audit procedures; linking destination-level sustainability indicators (such as those developed under the ETIS framework16) to quality labels without imposing them on individual businesses; establishing trusted public repositories for quality claims and audit outcomes, safeguarded under GDPR and DSA; and fostering cross-recognition of voluntary labels through mutual reference to shared standards. The ultimate objective is to strengthen the reliability of information available to consumers and to reduce compliance burdens for restaurant operators, while safeguarding Europe’s culinary diversity and preserving the freedom of entrepreneurial initiative. 16 European Tourism Indicator System (ETIS) is a voluntary tool developed by the European Commission to help tourism destinations monitor and manage sustainability performance. Its goal is not to certify or police destinations, but to provide a common, comparable framework of indicators (destination management, economic value, social & cultural impact, environmental impact), that destinations can use to assess economic, social, cultural and environmental impacts 612 AFONSO RIBEIRO CAFÉ
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