Etrawler Unlimited Company
CarTrawler is a B2B technology provider of car rental and mobility solutions to the global travel industry
ID: 624988052783-85
Lobbying Activity
Meeting with Kevin Barrett (Cabinet of Commissioner Michael McGrath) and EUROTRAN Conseil
26 Feb 2025 · Exchange on the Package Travel Directive
Response to Package travel – review of EU rules
13 Mar 2024
CarTrawler is the leading B2B technology provider of car rental solutions to the global travel industry and employs over 400 people almost all of whom are based in Ireland. We operate a three-sided online marketplace whereby our platform enables airlines and other partners to offer car rental to their customers as an ancillary product. Those customers can use the platform to book car rental with car rental suppliers worldwide with the ultimate contract for the rental of the car being between the car rental supplier and the customer. CarTrawler takes the payment from the customer and depending on the arrangement with the supplier, either pays the supplier up front or after the rental has taken place. Depending on the supplier, customers can cancel their booking free of charge 24 or 48 hours before the rental date. Refunds are paid to the customer within five business days of the cancellation. CarTrawler welcomes the revision of the Package Travel Directive (PTD) as an opportunity to rectify the unintended consequences of the introduction of Directive 2015/2302. While in certain circumstances where an airline offers car rental as an ancillary product it can constitute a package under Directive 2015/2302, in practice its provisions arent reflective of CarTrawlers ancillary car rental services model whereby it is CarTrawler and ultimately the car rental supplier that has the direct relationship with the customer for the car rental booking. CarTrawler collects payment directly from the consumer at the time of booking, while the airline, which is ostensibly the organiser of the package under the PTD, has no involvement at all in relation to the organisation of the car rental. As the airline isnt really the organiser of a package in this scenario, other than due to the operation of the PTD, this gives rise to a number of issues and complexities and these are unfortunately exacerbated by the proposal. These include: - Lower consumer protection under the PTD than under standard car rental business practices related to cancellation; and - The introduction of significant complexity which in practice is likely to be unworkable, such as: i. The proposed expanded definition of a package whereby an ancillary travel service booked with a different provider after the initial booking and where payment is made directly to that provider instead of to the organiser, can constitute a package; ii. the changes to the rules around downpayments for packages formed by later ancillary bookings; and iii. the rules on vouchers, which fail to take into account situations where payments for different services are made to each of the different service providers instead of the organiser. Given this complexity and the heavy administrative and integration requirements that would result from the legislative proposal, there is also a risk that consumers will no longer be able to benefit from ancillary car rental services. This would be to the detriment first and foremost of small, local car rental providers, as the larger car rental providers are more easily found online. It would also reduce competition in the broader online travel market, to the detriment of smaller travel providers and of consumer choice. Given the intricacies of the travel industry and the different types of service providers and models that exist in the market, applying a one-size fits all Directive to the industry as a whole, without a detailed assessment of the impact of this decision on the different types of service providers, can lead to suboptimal legislation that does not achieve the intended results and which ultimately reduces competition and consumer protection. Please see the enclosed document which sets out these challenges in more detail.
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