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The introduction of the Package Travel and Linked Travel Arrangements Regulations 2018 (2018 PTRs) presents major changes for businesses. Package holidays and Linked Travel Arrangements are often complex combinations of travel services which include transport and accommodation but may also include other services such as car hire and significant ‘other tourist services’ such as excursions. Different service providers, for example airlines and hotels, are often involved and a problem with the delivery of one service may affect the delivery of the others.

1. Do you organise packages?

It is important for businesses to understand whether the combination of travel services they arrange for consumers are packages or LTAs. The legal obligations will differ, including the requirement for insolvency protection.

2. Do you sell Linked Travel Arrangements?

Travel arrangements are ‘linked’ if the separate purchases were made during a single visit to a shop or website, or when a website ‘cross-sells’ a separate service on the back of the first. It is important to know the obligations for LTAs.

3. Information requirements

There is statutory information that must be provided in a clear, comprehensible and prominent manner in any materials presented to, or discussions carried out with, consumers prior to them making a package holiday or LTA.

4. Advertising and pricing requirements

There are clear regulatory requirements for advertising and pricing. These are the sources of most enforcement referrals and it is important to understand the need to provide information that is not only accurate, but also sufficiently comprehensive.

5. Payment surcharges and credit cards

Holiday and travel businesses are not permitted to impose surcharges for taking payment by a consumer debit or credit card, or an electronic payment service that is backed by a bank or an intermediary. Make sure you aren’t charging for these payments.

6. Complaint resolution

Dealing appropriately and quickly with complaints is not a statutory requirement but is good business practice. Complaints need not escalate into bad reviews or reputational damage if dealt with swiftly and honestly. Businesses that sell directly to consumer should be aware of alternative dispute resolution (ADR) schemes when they can’t resolve a dispute in-house.

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