Package travel reform and the UK by Christopher Deacon

when there is already so much more that needs to be done, for example on accessible air travel. While the UK government’s consultation proposed that consumers may benefit from increased choice because of reduced regulatory burdens, if the domestic only package reform were to be taken forward then 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 UK government’s response neatly summarises one of the fundamental aspects of consumer protection under the regulations, noting: “Moreover, where consumers have paid a single trader for the delivery of multiple services, they are likely to expect, and it is arguably equitable, that the trader will be liable for delivering those services.” VI. HOW SHOULD LINKED TRAVEL ARRANGEMENTS (LTAS) BE REGULATED? LTAs are formed when a combination of two or more types of travel services is linked, but sold separately under different contracts. The current definition of an LTA is complex, making it difficult for consumers to understand when they have purchased an LTA: • Type A LTAs involve the selection and payment of two or more services for the same trip, under separate contracts with individual providers, upon a single contact with a point of sale. • Type B LTAs involve the separate selection and payment of two or more travel services for the same trip through targeted linked booking processes within 24 hours without transferring the traveller’s payment details. When provided with a definition of an LTA, over 73% of respondents said that they still found the difference between an LTA and a package holiday confusing or that they did not understand at all.7 Even when further explanation was given, 46% of consumers still did not properly understand the protections. The nature and extent of consumer protections under LTAs are also complex. Consumers may mistakenly believe they are well-protected; however, unlike 7 Chartered Trading Standards Institute (CTSI) “Wish you were clear” poll, p.5 7 PACKAGE TRAVEL REFORM AND THE UK

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