Collective Commentary about the New Package Travel Directive

680 COLLECTIVE COMMENTARY ABOUT THE NEW PACKAGE TRAVEL DIRECTIVE In the latter part, the Guidelines respond to questions put forward by stakeholders.These practical applications provide slightlymore clarity concerning the way in which the legislation should be complied with. The questions relate to the application of information duties, the sale of insurance with a travel contract, changes to a travel contract, termination as a result of unavoidable and extraordinary circumstances, interpretation of a linked travel arrangement and so on. C.Guidelines: Exclusionof package travel offeredand linked travel arrangements facilitated, occasionally and on a not-for-profit basis and only to a limited group of travellers 19. Art 4. 2° – The Administration has also set up specific guidelines in which the emphasis is on exceptions that do not fall within the law’s scope of application, i.e. Art. 4. 2° of the new Travel Law. The article stipulates the following: “Packages offered, and linked travel arrangements facilitated, occasionally and on a not-for-profit basis and only to a limited group of travellers” is excluded. Exceptions to the Guidelines’, and consequently the Law’s, scope of the application must be interpreted precisely as intended. In order to better put this exception into perspective, the Guidelines initially clarify the main definitions of the legislation, then explain the principles of the Law and, finally, include practical applications. 20. Associations and NPOs – The separate guidelines for this exception came about as a result of a question from associations and NPOs that sporadically sell travel for their members or groups of people. European Directive 2015/2302/ EU and the Belgian transposition law do not pay sufficient attention to this exception, which can result in significant interpretation issues. The Guidelines of the FGD for Economic Affairs help NPOs and other associations to decide before making a sale whether they are subject to this new Law. The practical examples explain various situations and indicate for each of them whether or not they are subject to the transposition law. D. General Terms and Conditions of the Travel Arbitration Committee 21. Travel Arbitration Committee – The Travel Arbitration Committee NPO (hereafter referred to as TAC) was established in 1983, at the initiative of consumer organisations and professional associations, in the Belgian travel