Collective Commentary about the New Package Travel Directive

692 COLLECTIVE COMMENTARY ABOUT THE NEW PACKAGE TRAVEL DIRECTIVE The main provisions of the New Package Travel Directive (EU) 2015/2302 had been accurately reflected in the LawonTourism inBulgaria.The amendments in the law had been adopted and published later than the official date, namely on 4 May 2018 becoming effective on 1 July 2018. The Commission of Consumer Protection and the Ministry of Tourism are the authorities liable for their implementation in Bulgaria. 3. DISTINCTIVE FEATURES OF THE IMPLEMENTATION OF DIRECTIVE 2015/2302 IN BULGARIA There is no significant deviation in the transposition of the New Package Travel Directive in the Law on Tourism in Bulgaria. The relevant authorities had put all the necessary efforts into the transposition to mirror as closely as possible the original wording of the Directive. Nevertheless, there are some legal terms that can be better defined. The definition of some of the new forms covered by the Directive could have been transposed clearer, e.g. those purchased from separate traders through linked online booking processes. The Law on Tourism states that a contract has to be concluded with the trader or traders no later than 24 hours after the confirmation of the booking of the first travel service without specifying which trader or traders: the first or the latter one(s). This might lead to confusion in travellers’ conceptions, that if a contract is concluded with any trader within 24 hours it is automatically covered by the new provisions. The “start of the package” is defined in the Law on Tourism as “start of performance of each of the tourist services included in the package”. A travel package is usually activated with the start of the performance of the first service included in it which is traditionally the transportation service. A clarification of the start of the package needs to be done since this term plays a significant role in the articles related to price change policy, applicable cancellation fees, etc. There is a requirement so that the contact details of the insurance company are included in the package travel contract or in its confirmation, however, it needs to be better clarified that it is for the purpose of insolvency protection as stated in the Directive (EU) 2015/2302 and not for other insurance issues. Also, information about the name and contact details of the competent authority in Bulgaria concerned for such cases, namely the Ministry of Tourism and the Commission for Consumer Protection, needs to be added.