Collective Commentary about the New Package Travel Directive

598 COLLECTIVE COMMENTARY ABOUT THE NEW PACKAGE TRAVEL DIRECTIVE 3. EXCEPTIONS REGARDING THE ADDRESSES In certain exceptional cases, the directives may directly address EU citizens. In fact, in certain cases, the Court of Justice recognises the direct effect of directives in order to protect the rights of individuals. Therefore, it is possible for a directive to have direct effect when its provisions are unconditional and sufficiently clear and precise and when the EU country has not transposed the directive by the established deadline. However, directives can only have direct vertical effect and never horizontal effect 3 . Finally, EU countries are obliged to implement directives, but directives may not be used by an EU country against an individual. 3 Vertical direct effect means that individuals can invoke a European provision in relation to the country. Horizontal direct effect means that an individual can invoke a European provision in relation to another individual.