Collective Commentary about the New Package Travel Directive

838 COLLECTIVE COMMENTARY ABOUT THE NEW PACKAGE TRAVEL DIRECTIVE the vouchers for package travel at issue here, because the PTD is a subject to the primacy of Union law. Therefore, the Commission rightly rejected on 13 May 2020 vouchers for travellers if a package in its Recommendation (EU) 2020/648 on vouchers for passengers and travellers places them as an alternative to reimbursement for cancelled Package travel 47 . Vouchers must in any case be voluntary and protected against insolvency. Consequently, on 2 July 2020 the Commission called 10 Member States in accordance with Art. 258 TFEU to inform them they are violating Art. 12 (4) PTD 48 . The German voucher regulation provides that tour operators offer customers free vouchers according to the value of the tour price, instead of the immediate reimbursement for packages booked before 8 March 2020, which cannot be carried out due to the COVID-19-Pandemic. The organiser must expressly inform the customer of his right to choose. In addition to the insolvency protection, according to § 651r BGB, the German government wants to guarantee the value of the voucher up to the full amount by means of an additional protection. If the voucher is not redeemed by the end of 2021, the value of the original tour price must be paid out immediately. 47 See https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32020H0648. 48 See https://ec.europa.eu/commission/presscorner/detail/en/inf_20_1212.