This liability, however, is easy to avoid: it is sufficient to explicitly and clearly mention on the ticket, or on another document or electronically in a manner that allows the passenger to reproduce the information for future reference, that the combined multimodal ticket consists of separate transport contracts with no right under this Regulation to reimbursement, re-routing, assistance or compensation in case of missed connections. Of this, the passenger has to be clearly informed prior to the purchase.84 For the category of separate multimodal tickets, the Proposal contains a definition, but no legal consequences linked to it. Why this category exists at all therefore remains questionable. 3.3. General Provisions The general provisions of the proposal concern a ban on direct or indirect discrimination on the basis of the passenger’s nationality or of the place of establishment within the Union of the carrier or intermediary,85 information obligations of carriers and intermediaries before and during the multimodal journey86 and access of other carriers and intermediaries to information,87 non-discrimination of persons with disabilities or reduced mobility88 and information89 and assistance90 to these persons. As the poposal for the amendment of the various passenger rights regluations, the proposed regulation on multimodal journeys also contains provisons on service quality standards,91 complaint handling,92 information and enforcement.93 3.4. Conclusions It is to be welcomed that the Commission is attempting to close the protection gap that can arise when different modes of transport are used in succession. However, from the PTD 2015, the European legislator could have learned that complex concepts don’t work out in practice. It could also have been understood that companies are only too happy to make use of exemptions and that an easily implemented exception can therefore remove any practical relevance from a rule. 84 Article 10(2) CP 2023 MMJ. 85 Article 4(1) CP 2023 MMJ. 86 Article 5 CP 2023 MMJ. 87 Article 6 CP 2023 MMJ. 88 Article 12 CP 2023 MMJ. 89 Article 13 CP 2023 MMJ. 90 Article 14 CP 2023 MMJ. 91 Article 17 CP 2023 MMJ. 92 Article 19 CP 2023 MMJ. 93 Articles 21 to 25 CP 2023 MMJ. 20 MICHAEL WUKOSCHITZ
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