Collective Commentary about the New Package Travel Directive

544 COLLECTIVE COMMENTARY ABOUT THE NEW PACKAGE TRAVEL DIRECTIVE deletion of Article 3(2)(b)(v) as they considered it as too complex and hardly used. The Expert Group highlighted that rather than the definition itself, it is the delimitation between packages booked online from a single point of sale (and not through a linked online “click-through” booking process) and the facilitation of the separate selection and payment of travel services in the form of a linked travel arrangement which is challenging for the industry, but also for consumers who may not be aware of the change brought by the Package Travel Directive. There is therefore a strong call from stakeholders and authorities for guidance on the application of the current rules to bring more clarity, legal certainty and uniformity, which could be more helpful than legislative changes at this stage. In addition, although this was not raised during the stakeholder consultation and discussions in the Expert Group, the application of the Package Travel Directive to online intermediation services, comparison sites and search engines may also need to be further studied 14 . 14 See Staff Working Document SWD(2019)270, p. 5.