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HOTREC, Hotels, Restaurants & Cafés in Europe

HOTREC

HOTREC represents hotels, restaurants and cafés across Europe, bringing together 46 national associations from 35 countries representing around 2 million businesses (99% SMEs).

Lobbying Activity

Meeting with Alicia Homs Ginel (Member of the European Parliament)

14 Jan 2026 · Position on Short-Term Rentals

Meeting with Gordan Bosanac (Member of the European Parliament)

14 Jan 2026 · Exchange of views of STRs in the new HOUS report and the Affordable Housing Plan

Meeting with Isabelle Perignon (Director Justice and Consumers)

18 Dec 2025 · Exchange of views on the HOTREC position paper in reply to the public consultation on the Digital Fairness Act (DFA)

Meeting with Sophia Kircher (Member of the European Parliament)

11 Dec 2025 · EU Tourism strategy

Meeting with Pierfrancesco Maran (Member of the European Parliament)

12 Nov 2025 · Short term rentals

Meeting with Philippe Moseley (Cabinet of Commissioner Dan Jørgensen)

6 Nov 2025 · Housing

Meeting with Alex Agius Saliba (Member of the European Parliament, Rapporteur) and ECTAA, Group of National Travel Agents' and Tour Operators' Associations within the EU

4 Nov 2025 · Package Travel Directive

Meeting with Borja Giménez Larraz (Member of the European Parliament)

2 Oct 2025 · Priorities in tourism sector

Meeting with Arash Saeidi (Member of the European Parliament)

24 Sept 2025 · exchange views on the sector’s future, addressing skills gaps, affordability, innovation, and sustainability

Meeting with Daniel Attard (Member of the European Parliament, Rapporteur)

22 Sept 2025 · Sustainable Tourism Report, STR, hotelier sector, tourism strategy

Meeting with Alicia Homs Ginel (Member of the European Parliament, Rapporteur) and BUSINESSEUROPE

15 Sept 2025 · Traineeships Directive - State of play

Meeting with Angelika Winzig (Member of the European Parliament)

3 Jul 2025 · Meeting with a representative of HOTREC

Meeting with Luis Planas Herrera (Cabinet of Commissioner Jessika Roswall)

18 Jun 2025 · Circularity agenda

Meeting with Nikolina Brnjac (Member of the European Parliament)

10 Jun 2025 · EU Tourism Agenda 2024–2029

Meeting with Johan Danielsson (Member of the European Parliament)

6 Jun 2025 · Kampen mot arbetslivskriminalitet

Response to European Affordable Housing Plan

4 Jun 2025

Please see the document attached with HOTREC's feedback.
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Meeting with Arba Kokalari (Member of the European Parliament, Shadow rapporteur)

3 Jun 2025 · Green Claims Directive

Meeting with Elena Nevado Del Campo (Member of the European Parliament)

22 May 2025 · Real Decreto 933/2021

Meeting with Marie-Hélène Pradines (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

15 May 2025 · Hotrec has requested a meeting to learn about Commission’s activities for SMEs and possibilities to contribute to policymaking in this area

Meeting with Yannis Maniatis (Member of the European Parliament)

16 Apr 2025 · Introductory Meeting

Meeting with Taru Haapaniemi (Cabinet of Commissioner Christophe Hansen)

26 Mar 2025 · Resilient and Sustainable EU Food System; introduction of the organisation and raising awareness for the hospitality sector

Meeting with Egelyn Braun (Cabinet of Commissioner Michael McGrath)

20 Mar 2025 · Exchange on consumer policy files

Meeting with Dimitris Tsiodras (Member of the European Parliament)

19 Mar 2025 · EU digital and consumer policies

Meeting with Denis Nesci (Member of the European Parliament)

18 Feb 2025 · Package travel

Meeting with Nikolina Brnjac (Member of the European Parliament, Shadow rapporteur for opinion) and ECTAA, Group of National Travel Agents' and Tour Operators' Associations within the EU

17 Feb 2025 · Package Travel Directive

Meeting with Dennis Radtke (Member of the European Parliament)

13 Feb 2025 · Arbeitskräftemangel und Beseitigung von Qualifikationsdefiziten

Meeting with Angelika Winzig (Member of the European Parliament)

12 Feb 2025 · Meeting with a representative of HOTREC

Meeting with Arba Kokalari (Member of the European Parliament, Shadow rapporteur) and Visita

11 Feb 2025 · Package Travel Directive

Meeting with Alicia Homs Ginel (Member of the European Parliament, Rapporteur)

4 Feb 2025 · Effects of the Traineeships Directive for the hospitality industry

Meeting with Pietro Fiocchi (Member of the European Parliament, Shadow rapporteur for opinion)

30 Jan 2025 · Asserzioni ambientali

Meeting with Rosa Serrano Sierra (Member of the European Parliament) and European Passengers' Federation

30 Jan 2025 · Priorities for European Commission 2024-2029

Meeting with Cynthia Ní Mhurchú (Member of the European Parliament, Shadow rapporteur) and International Road Transport Union Permanent Delegation to the EU and

30 Jan 2025 · Package Travel Directive

Meeting with Ioan-Dragos Tudorache (Cabinet of Executive Vice-President Stéphane Séjourné)

28 Jan 2025 · Discussion on the competitiveness of the tourism sector

Meeting with Johan Danielsson (Member of the European Parliament)

27 Jan 2025 · Arbetsmarknads- och inremarknadsfrågor

Meeting with Valérie Deloge (Member of the European Parliament, Shadow rapporteur)

27 Jan 2025 · Application de la Directive allégations vertes au secteur de l'HORECA

Meeting with Paulo Cunha (Member of the European Parliament)

14 Jan 2025 · EU talent pool

Meeting with Emma Wiesner (Member of the European Parliament, Shadow rapporteur)

12 Dec 2024 · Green Claims

Meeting with Sandro Gozi (Member of the European Parliament, Rapporteur)

5 Dec 2024 · Green Claims Directive

Meeting with Chiara Gemma (Member of the European Parliament, Shadow rapporteur)

5 Dec 2024 · Traineeship directive

Meeting with Arash Saeidi (Member of the European Parliament)

3 Dec 2024 · reception

Meeting with Sophia Kircher (Member of the European Parliament)

20 Nov 2024 · Green Claims, Package Travel Directive

Meeting with Daniel Attard (Member of the European Parliament)

11 Oct 2024 · Priorities for HOTREC

Meeting with Elena Kountoura (Member of the European Parliament)

4 Oct 2024 · Meeting with HOTREC representatives

Meeting with Arba Kokalari (Member of the European Parliament, Shadow rapporteur) and Visita

3 Oct 2024 · Package Travel Directive

Meeting with Danuše Nerudová (Member of the European Parliament, Shadow rapporteur) and AIM - European Brands Association

1 Oct 2024 · discussion about Green Claims Directive

Meeting with Sérgio Gonçalves (Member of the European Parliament)

26 Sept 2024 · Priorities for this mandate in the TRAN Committee

Meeting with Arash Saeidi (Member of the European Parliament)

17 Sept 2024 · Présentation de l'association et des questionement du secteur du HCR

Meeting with Nikolina Brnjac (Member of the European Parliament)

3 Sept 2024 · Priorities of European hospitality sector

Meeting with Josianne Cutajar (Member of the European Parliament)

10 Jul 2024 · EU tourism policy during the 9th legislature

Meeting with Ivan Štefanec (Member of the European Parliament)

11 Apr 2024 · HORECA sector outlook

Meeting with Josianne Cutajar (Member of the European Parliament) and ECTA

3 Apr 2024 · Celebrating five transformative years of EU tourism policy

Meeting with Antoine Kasel (Cabinet of Commissioner Nicolas Schmit)

29 Feb 2024 · labour shortages

Meeting with Liliane Karlinger (Cabinet of Executive Vice-President Margrethe Vestager), Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

7 Feb 2024 · DMA

Meeting with Róża Thun Und Hohenstein (Member of the European Parliament, Shadow rapporteur)

24 Jan 2024 · Waste Framework Directive revision

Meeting with Abir Al-Sahlani (Member of the European Parliament, Rapporteur)

23 Jan 2024 · Möte om Talent Pool

Meeting with Josianne Cutajar (Member of the European Parliament)

29 Nov 2023 · European Hospitality Day 2023: unveiling HOTREC's Manifesto

Meeting with Ilan De Basso (Member of the European Parliament)

26 Oct 2023 · Panel

Meeting with Maurits-Jan Prinz (Cabinet of Commissioner Thierry Breton)

25 Oct 2023 · Tourism policy and platform regulation

Meeting with Laura Ballarín Cereza (Member of the European Parliament, Shadow rapporteur)

13 Oct 2023 · Green Claims

Meeting with Cyrus Engerer (Member of the European Parliament, Rapporteur) and FoodDrinkEurope and World Travel and Tourism Council

28 Sept 2023 · Green Claims Directive

Meeting with Andrus Ansip (Member of the European Parliament, Rapporteur) and AIM - European Brands Association and CEPI Eurokraft

5 Jul 2023 · Green Claims

Meeting with Ilan De Basso (Member of the European Parliament) and AXA and Association of Charity Lotteries in Europe

5 Jul 2023 · Möte

Response to Guidelines on exclusionary abuses of dominance

24 Apr 2023

HOTREC, the voice of European hospitality, welcomes the opportunity to provide feedback on the call for evidence on guidelines on exclusionary abuses by dominant undertakings. For over a decade, HOTREC has been paying particular attention to the role of online travel agencies (OTAs) and the treatment of the hotel businesses of which the majority of them are small and medium-sized enterprises. The hotel industry in Europe is still more than concerned about the imbalance between the highly concentrated OTAs on the one hand and the strongly fragmented hotel industry on the other, which is increasingly dependent on the access to these online portals. More and more hotels are finding it difficult to withstand the pressure of the dominant OTAs in the field of online distribution and are forced to accept terms and conditions that they would not accept under normal market conditions. Thus, more and more hotels are losing control over their own product. Since 2013, HOTREC has in collaboration with the University of Applied Sciences of Western Switzerland Valais (HES-SO Valais Wallis) bi-annually conducted the hotel distribution study. The objective of the study is to monitor the evolution of distribution channels used to reserve hotel rooms within the European hotel industry with a specific focus on the role of OTAs. More detailed feedback is available in the attached file.
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Meeting with Brando Benifei (Member of the European Parliament, Shadow rapporteur)

20 Apr 2023 · "Short-term rentals" file in IMCO (meeting held by assistant responsible)

Meeting with Salvatore De Meo (Member of the European Parliament, Rapporteur) and EUMEPS and Polymateria Limited

21 Mar 2023 · PPWR

Meeting with Ralf Kuhne (Cabinet of Commissioner Stella Kyriakides)

21 Mar 2023 · Meeting on food waste reduction

Meeting with Alicia Homs Ginel (Member of the European Parliament)

21 Mar 2023 · Regulation of short-term accommodation rental services

Meeting with Ivan Štefanec (Member of the European Parliament)

15 Mar 2023 · Packaging and Packaging Waste Regulation

Response to EU Talent Pool

13 Mar 2023

HOTREC considers that building an EU Talent Pool, connecting the EU employers with third-country nationals willing to work in the hospitality sector, can be part of the solution to the labour and skills shortages existing in the sector. First of all, HOTREC would recommend that lessons learned from the EU talent pool pilot with Ukraine would be taken into consideration. HOTREC would also be interested to know about the outcome of the pilot. We consider that the EU Talent Pool should be, above all, very user friendly, non-bureaucratic, even captivating, so that both potential employers and employees are keen to use. It should be business oriented, as the end users will be both employers and potential workers. We are also of the opinion that the low and medium skilled should be allowed in the EU Talent Pool. The hospitality sector is in need of high and medium skilled (e.g. chefs; professionals dealing with digital marketing skills; languages; soft skills.) But it is to note that 30% of our employees are relatively unskilled (while their tasks are very relevant to the good performance of the sector). Examples cover professionals dedicated to cleaning activities, waiters or kitchen support professionals. Therefore, low skills are also needed. From the possibilities presented by the European Commission, HOTREC would support a combination of both Option 3 (developing an EU Talent Pool open to all Member States for targeted labour migration purposes (legislative option) and Option 4 (developing a fully self-standing and mandatory EU Talent Pool, for all labour migration purposes (legislative option). With regard to option 3, we consider positive that the EU Talent Pool would be linked to the Partnership Agreements and that, therefore, the EU Tool would not be open to all third-country nationals, but limited to third country nationals from identified partner countries, where main objectives of cooperation have been established. This would also mean that there would be pre-screened candidates that meet certain criteria. This would save time to employers looking for the correct skills, and to potential employees (it should not be possible to to fill in data, if not part of a certain selection criteria). We also very much support the voluntary nature of the system. Nevertheless, we have doubts on weather EURES should be the tool to be used for the automatic matching. According to our information, EURES is not very much used by our members. A tool that is closer to business and more efficient in the matching needs of the sector could be envisaged. The tool could eventually be based on the skills of the potential workers (inspiration could be taken from the European Hospitality Skills Passport, developed both by HOTREC and its trade union counter-part, EFFAT, under the umbrella of the European Commission DG EMPL. The tool put in contact both employers and employees in the hospitality sector. The platform is no longer live). With regard to option 4, we welcome that a new IT solution would be created. Nevertheless, we dont agree that the tool is mandatory to all Member States. All these procedures should be dealt with by Member States on a voluntary basis. Sectors that have been identified as lacking labour/skills, should be included in the tool (namely the hospitality sector). In any case, we agree that an EU Talent Pool includes administrative processes to pre-screening candidates; the validation of candidates skills and qualifications; interoperability with other international recruitment tools and national platforms. For the system to work, third countries should be informed about the skills shortages and vacancies in the sectors. We also consider that a clear separation between sectors should be established, so that vacancies for each one of the sectors are easily found. HOTREC reiterates its willingness to encourage legal migration, and is ready to be engaged in a dialogue with the European Commission on the matter.
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Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and BUSINESSEUROPE and

8 Mar 2023 · Corporate Sustainability Due Diligence

Meeting with Kim Van Sparrentak (Member of the European Parliament, Rapporteur)

7 Mar 2023 · short-term accommodation rental services

Meeting with Luisa Regimenti (Member of the European Parliament, Shadow rapporteur) and European Ceramic Industry Association and

7 Mar 2023 · PPWR

Meeting with Maurits-Jan Prinz (Cabinet of Commissioner Thierry Breton)

28 Feb 2023 · EU tourism ecosystem & SME policy

Meeting with Frédérique Ries (Member of the European Parliament, Rapporteur)

7 Feb 2023 · PPWR

Response to Short-term rental initiative

12 Jan 2023

HOTREC, the voice of European hospitality, welcomes the proposal for Regulation on Short-Term Accommodation Rentals which sets common rules for host registration and a data-sharing framework with public authorities. The initiative represents an important step in establishing a framework that will protect and benefit consumers, residents, hospitality workers, local communities and the entire EU tourism ecosystem of which short-term rental (STR) accommodations have, over time, become an inherent part. HOTREC has been closely following the developments and latest trends of STRs for almost a decade, and with great concern, we can conclude that the problems of STRs identified in the past remain relevant today: unfair competition, undeclared work, consumer exposure to safety hazards and unreported tax income, among other things, remain outstanding issues. We, therefore, welcome that the current proposal will become an important tool for authorities around the EU to address many of these issues. With that in mind, HOTREC also supports that the proposal is based on the principle of subsidiarity and that local, regional and/or national authorities will remain empowered to introduce market access rules. Nevertheless, HOTREC believes that the current proposal should be further strengthened and clarified so that the final law is future-proof and helps to level the playing field amongst different accommodation providers. We, therefore, call on the EU Member States and the European Parliament to address the following issues which are further elaborated on in the second part of the position paper: 1. Scope and definitions (such as unit) should be clarified by referencing national laws. 2. Registration schemes and registration numbers for hosts should be mandatory in all EU Member States. 3. More flexibility and ambition should be given when it comes to data and information provided by hosts. 4. The roles and responsibilities of online platforms should be strengthened with an aim of supporting regulatory compliance by STR hosts. More information is available in the attached position paper.
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Meeting with Antoine Kasel (Cabinet of Commissioner Nicolas Schmit), Christoph Nerlich (Cabinet of Commissioner Nicolas Schmit)

29 Jun 2022 · Meeting on the hospitality sector willingness to support refugees

Meeting with Elisabetta Gualmini (Member of the European Parliament, Rapporteur) and European Youth Forum and

12 Apr 2022 · 2nd roundtable on platform work directive

Response to Sustainable food system – setting up an EU framework

26 Oct 2021

• Sustainability is of vital importance and we encourage industry’s action in line with the “European Green Deal” • We are of the opinion that sustainability labelling of food products in gastronomy should not be mandatory. The culinary identity of the Member States should be preserved. We support voluntary action for those companies who accept higher costs and are able to assume a competitive advantage when compared to other businesses. The additional administrative effort that a compulsory labelling would entail for the domestic gastronomy businesses would be enormous (and let’s not forget the sector is still in survival mode due to COVID-19). In any case, if there is an increased demand for sustainable products and the willingness for customers to afford them, businesses will adapt; • Incentives (e.g. reduced or zero VAT) should be provided to companies (especially micro-entreprises and SME’s) and producers: the Commission mentions that sustainable options are generally more expensive for consumers. However, in the economic impact section, the Commission highlights possible higher food prices for consumers and lower margins for suppliers, at least in the short-term. We believe that there needs to be a stronger emphasis on financially supporting sustainable options to bring their prices more in line with regular (less sustainable) options. Prices affect consumer behaviour and this is needed to achieve substantial change, at least until the prices of sustainable options naturally decrease due to technological improvements and scale. • All new instruments, like a general minimum standard or a voluntary sustainable food labelling system, should be supported by substantial scientific knowledge. Otherwise, there is a danger of greenwashing (e.g. fictious benefits), which would cause useless costs and administrative burdens to enterprises (especially micro-enterprises – 90% of the sector); • A lot of work is currently being done at EU level and in Member States to improve the level of knowledge and to get a better overall vision on sustainable food systems. Thus, we consider it is too early to set any general standards or specific responsibilities to food system actors; • The key factors towards reduced food waste and sustainable food systems in restaurant operation are educating personnel in proper procurement and food service. Information provided on a voluntary basis on portion sizes and ingredients might be helpful. • As the topic is not simple, actions to solve it may cause conflicting and even unwanted consequences. For example, it is mentioned in the chapter “Likely social impacts” of the inception impact assessment, that improved sustainability of the food system is expected to boost local businesses and food production. The opposite effect may be possible, too: the new requirements may benefit large, international producers, which have better possibilities to adjust their operations; • The restaurant sector is very dependent on other sectors of the food value chain. Most of the environmental impacts of food are formed earlier in the chain, especially by the choices made in the primary production sector. Thus the actions of restaurants have only a limited influence; • The restaurant sector is also dependent on the choices of the customers. Measures like minimum mandatory criteria for sustainable food procurement in schools (combined with teaching and education) could be effective to influence the behaviour of the future customers. For instance, training material on the value of consuming less meat and more fruit/vegetables/fish/nutrition value and sustainable farming would be welcoming. Training on nutritional habits for young people can make a difference; • With regard to food waste, smart indicators providing information on the microbiological condition of each food, before it is decided that it belongs to a food waste could be helpful;
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Response to Food waste reduction targets

22 Oct 2021

It is to note that food services are responsible for only 12% of the total food waste produced in the EU. In fact, hospitality represents only a small share of this percentage, as food services include sectors not covered by our sector (e.g. party catering; contract catering in hospitals, schools, public institutions). Therefore, our fair share of responsibility is limited. Despite this, HOTREC is fully committed to encourage and help its members decrease food waste. In this context, HOTREC is an active member of the EU Platform on Food Loss and Food Waste, which included work on co-drafting the EU Recommendations on Food Loss and Food Waste; encouraging members to implement them at national level; sharing, collecting and disseminating best practices with members on food waste. While we understand that the European Commission needs to define the level of reduction for different stages of the food supply chain, we believe that these targets need to be indicative and not mandatory at national level. It is in the interest of companies to reduce food waste, both from an environmental as well as an operational perspective. But national binding targets would penalise responsible enterprises that already undertook efforts to reduce food waste, and which would find it difficult to reduce it further. Moreover, it is to note that 99 % of our companies are SME’s (and 90% are micro-enterprises). Our members inform us that small companies do not have the space to measure the food waste in their premisses; nor the technical skills required from the employees to carry on the measurement. It would also be very challenging to implement further administrative or financial measures that, in time of crisis, are even more difficult to deal with. Also, food waste in gastronomy should not be assessed in a general way, but a distinction should be made between "avoidable" waste (what is left over by guests) and "unavoidable" waste (what is inevitably produced during cooking). Unavoidable waste can hardly be reduced. Overall, we consider that the initiative should create a conscious use of food and resources among the population. This can be done, for example, through accurate information on the topic of waste reduction in various media as well as through education in kindergartens and schools. We welcome the fact that each Member States would be able to choose the most effective measures taking into account its specific national situation (e.g. improving knowledge on levels and impact of food waste; influencing attitude and behaviors; encouraging less wasteful practices). We also appreciate the inclusion of rewarding provisions (i.e. reduced garbage fee) for subjects that demonstrate compliance with the recommendations against food waste. We support a path of rewarding policies by the Commission. With regard to the baseline scenario presented by the Commission, HOTREC believes the best option is as follows: • Scope – option S2 - Target covering only selected stages of the food supply chain Justification: the proportionality principle should be considered. Sectors that produce less food waste, should be less targeted. • Expression – option E2 – targets expressed as absolute amounts, i.e. in kilograms per capita per year to be achieved by 2030 (per country) Justification: targets expressed in % of food waste reduction might not be realistic and more difficult to comply by companies. • The way targets are set for Member States – collective target on EU level – based on Member States contributions Justification: the common joint output will help reach the UN target of reaching 2050 carbon neutrality by 2050.
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Response to Short-term rental initiative

14 Oct 2021

HOTREC welcomes the intention to create new legislation establishing an Internal Market framework for the provision of STR services in the EU. HOTREC agrees with the Inception Impact Assessment document’s proposals, including the scope, covering both (i) access to data and (ii) market access conditions. HOTREC also agrees that the initiative should not address urban planning rules and zoning requirements, in line with the principle of subsidiarity. HOTREC however questions some assertions made in the document regarding the contribution of STR to jobs, SME activity and the recovery of tourism. The contribution of STR to jobs and outsourced activities for SMEs is marginal, especially when compared to traditional accommodation service providers. Where STR hosts do create jobs and outsource activities, they will typically be providing a ‘professional service’ which is particularly unfairly underregulated compared to the traditional accommodation services. We consider that a level playing field between STR and traditional accommodation is an essential element to support the recovery of the tourism ecosystem and boost its major contribution to jobs and growth in the EU. Furthermore, while we recognise that this initiative would address the fragmentation of rules applicable to STR, a level playing field implies that STR must be exposed to what STR market players may consider as “burdensome and restrictive rules”. STR rules are necessary to i.a. protect the health and safety of guests, ensure liability and the collection of due taxes, avoid pressure on housing markets and nuisances for local residents. The legislative initiative should provide a clear framework for local, regional and national authorities addressing how regulatory schemes can be elaborated, managed and enforced, and how STR activities in their jurisdiction can be overseen. Local, regional and national authorities should be empowered to determine which type of rules need to be elaborated and applied, in line with the principle of subsidiarity. Registration and prior authorisation schemes for STR run by public authorities are essential and should be mandatory across the EU. The registration and authorisation process should cover all required verifications and background checks (e.g. consultation of immediate neighbours, compliance with health and safety requirements, fiscal status and information). STR properties and hosts need to be properly recognised and accounted for through an official, publicly available register. The legislative initiative should not prevent public authorities, should they see the need to do so, from significantly restricting or limiting STR activities. The initiative should clarify which type of data should be provided by STR platforms and hosts to public authorities and how the data should be provided. Data exchange requirements should be clearly explained to STR hosts as part of the registration and authorisation process. Public authorities may also require additional training and skills to use data provided. Intermediary platforms should play a central role as facilitators by providing all necessary data, backed by stringent data exchange rules if necessary. Data should be provided to tax authorities to ensure that STR-generated income is appropriately scrutinised and taxes are paid in a timely and efficient manner. HOTREC considers that differentiating hosts offering STR on an occasional basis from hosts offering services on a professional or quasi-professional basis is necessary. Caps can be of particular importance in high-density areas to limit the negative impacts of STR on the housing market. However, caps tend to be easy to circumvent and difficult to monitor for authorities. The Digital Services Act should put public authorities is a key position to identify and flag STR offers which do not meet regulatory requirements, and intermediary platforms should remove such offers diligently and swiftly.
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Meeting with Marian-Jean Marinescu (Member of the European Parliament)

6 May 2021 · Hospitality sector in Europe

Response to Setting of nutrient profiles

1 Feb 2021

HOTREC is the umbrella association of Hotels, Restaurants and Cafés in Europe. Please find the document enclosed with our position on the European Commission's Inception Impact Assessment.
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Response to Collective bargaining agreements for self-employed – scope of application EU competition rules

1 Feb 2021

HOTREC is the umbrella association of Hotels, Restaurants and Cafés in Europe. Please find enclosed HOTREC's comments on the European Commission Inception Impact Assessment on collective bargaining and the self-employed.
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Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

30 Nov 2020 · Digital Services Act

Response to Revision of the Vertical Block Exemption Regulation

20 Nov 2020

Please see attached file.
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Meeting with Nicolas Schmit (Commissioner) and

29 Oct 2020 · Pact for Skills Roundtable with the tourism sector

Meeting with Thierry Breton (Commissioner) and

29 Oct 2020 · Pact for Skills: Roundtable with tourism sector

Meeting with Cláudia Monteiro De Aguiar (Member of the European Parliament)

11 Jun 2020 · Establishing an EU Strategy for Sustainable Tourism - Rapporteur

Meeting with Gaelle Garnier (Cabinet of Commissioner Thierry Breton), Valère Moutarlier (Cabinet of Commissioner Thierry Breton) and

7 Apr 2020 · Impact of Covid-19 crises on Tourism

Response to Farm to Fork Strategy

13 Mar 2020

As the voice of the European hospitality sector (hotels, restaurants, cafés and similar establishments), HOTREC and its 45 member associations representing the hospitality sector in Europe welcome the intention to make EU food systems more sustainable and make it contribute to achieving the UN Sustainable Development Goals. An in-depth reflection is indeed needed about how to better respond to consumers’ growing demand for a sustainable food chain, knowledge about origin of food products and health aspects and about how to further boost food waste reduction. HOTREC considers that the hospitality sector faces unique challenges in the food chain to answer these demands, because of the characteristics of the sector (regular change of ingredients and supplies, use of fresh products to prepare food for immediate consumption, use of local and high quality artisanal food products, absence of standardisation of the dishes to guarantee high level gastronomic experiences, etc.). HOTREC considers that the farm-to-fork strategy should promote the sourcing of high-quality artisanal food to hospitality businesses. Moreover, additional information obligations on non-prepacked food represent a massive challenge for restaurants with negative consequences on quality and culinary excellence, especially as written information obligations are simply impossible to handle. Smarter approaches should be used for non-prepacked food served in restaurants (e.g. through the assignment of general objectives to Member States to be achieved through flexible national measures of their choice to be agreed through national consultation with the sector). Reducing food waste must also be a priority, but caution is needed about the negative unintended effects of binding food waste reduction targets. Instead a strong support for a swift implementation of the recommendation for actions adopted by the EU Food losses and food waste platform on 12 December 2019 is needed. This should be seen as a trop priority issue for the European Commission. A more detailed feedback is attached.
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Response to Strengthening the principle of equal pay between men and women through pay transparency

22 Jan 2020

HOTREC is the umbrella Association of hotels, restaurants, bars and cafés in Europe, which brings together 45 national associations in 33 European countries. Please find in the document enclosed HOTREC's contribution to the Commission roadmap on the inception Impact Assessment on "Strengthening the principle of equal pay between men and women on pay transparency"
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Response to Establishment of a methodology of measurement of food waste

4 Apr 2019

HOTREC is the umbrella association representing the European hospitality sector (hotels, restaurants, bars, cafés and similar establishments), a sector made of 2 million businesses providing 11,9 million jobs and a key component of the food chain. As a member of the EU platform on food losses and food waste, HOTREC participated to the various exchanges of views held within the EU platform on the outline of the EU methodology. Overall, HOTREC welcomes the common EU methodology for quantifying food waste. In particular, HOTREC welcomes that the methodology proposes not to count: - Food waste residues part of street cleaning residues (article 1-4-d). Indeed, the overall quantities of such food waste are marginal and cannot be attributed with certainty to one stage of the food chain/one sector in the food chain in particular; - Food waste drained as or with wastewater (e.g. residues of drinks – see article 1-5-a). Indeed, there are currently no methods for measuring such waste with a sufficient levels of confidence and comparability, while their measurement would represent a strong disproportionate burden. HOTREC also welcomes article 2 of the draft Commission delegated decision, which states that: - Member States shall measure each year the amount of food waste generated (article 2-1) - In depth measurement of food waste in a given stage shall be made (through the methodology set-out in annex III) at least once every 4 years, while in the interval, other methods (see annex IV) are proposed for a less in-depth measurement. The frequency foreseen for in-depth measurement seems reasonable and should avoid disproportionate burdens, while ensuring measurement of reliable trends between two in-depth measurements. Concerning annex III of the Commission delegated decision (methodology for in-depth measurement): - HOTREC welcomes that Member States be given the choice among different methods of measurement to evaluate food waste in restaurants and food services (e.g. waste compositional analysis, counting/scanning, diaries). - HOTREC welcomes that annex III does not name which entity should perform physically the measurement in the representative sample of food business operators. Indeed 90% of hospitality businesses are micro-enterprises. While some hospitality businesses may be able on a voluntary basis to take part in food waste measurement, a majority of these businesses do not have the internal resources to measure themselves food waste. The flexibility in the choice of the measurement method and the absence of identification of the entity in charge of the measurement will allow Member States to adjust their strategy of food waste measurement in the food service sector, so as to tailor it to the national specificities of the sector. This flexibility is strongly welcomed.
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Response to Summertime consultation

12 Nov 2018

HOTREC good notes of the Commission proposal and considers the following: • A uniform and harmonised approach to seasonal time arrangement is vital for the tourism sector, as tourism relies on a complex interaction of different operators established in different countries who need to work in a coordinated approach. A lack of uniformity would bring important disruptions. • Should seasonal time changes be abolished, HOTREC supports sticking to summer time, as this would benefit the tourism and hospitality sector, through a longer use of terraces and outdoor seating in the evening. • Permanent wintertime should be avoided, as this would negatively impact the revenues of the tourism and hospitality industry: earlier sunsets would mean a potential loss of revenues, especially in the northern part of Europe where daylight hours are strongly reduced. Additional details are available in the position attached.
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Response to Establishing a legal limit for the industrial trans fats content in foods

29 Oct 2018

HOTREC welcomes the focus of the Commission proposal on industrial transfats only, leaving out of the scope naturally occuring transfats (their inclusion would have been impossible to implement in the hospitality sector, while being rejected by most consumers). However, HOTREC considers that the current wording should be made clearer: the proposed wording on the scope gives the impression that only the actual fat of animal (e.g. speck) are to be exclused from the scope, while the intention is clearly to leave out of the scope all transfats naturally present in fat of animal origin (e.g. butter, milk, cream, etc.). Besides, HOTREC strongly questions the focus on food intended to the final consumer only. Restaurants do not produce themselves industrial transfats. If some industrial transfats are present in a meal served in a restaurant, it is because they are already contained in the supplies/ingredients the restaurant received. A legal limit applying exclusively to foods intended to the final consumer would shift the responsibility away from the business which produced the transfats (the food processing business which incorporated transfats into an ingredient) to restaurants which do not produce industrial transfats and which have no choice but to use the ingredients provided to them. As many ingredients supplied to restaurants may not necessarily be available for the final consumer this is unworkable: restaurants are not in a position to request from suppliers foods compliant with the legal limit, the information about the exact TFA content of an ingredient is not provided to a restaurant and restaurants (the vast majority of which being micro-enterprises producing non standardised food) do not have the mean to test every batch of ingredients and meals. HOTREC therefore requests that the scope of application of the legal limit be amended to cover all food/fats/oils intended for human consumption or intended to be incorporated in food presumed to be consumed by consumers. A detailed position is attached.
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Response to Reducing marine litter: action on single use plastics and fishing gear

18 Jul 2018

As Single Use Plastics represents about half of all marine litter items found on beaches in Europe, HOTREC supports taking strong actions to reduce their impact on the environment. This is necessary to preserve Europe’s tourism ecosystems and competitive advantage. Nevertheless, replacing single-use plastics will be a difficult task for many small hospitality businesses which commonly use single-use straws, plates, glasses, food containers and cutlery, in particular for take-away food services and external catering events. Indeed, there are currently no satisfying alternatives to single-use plastic food containers and beverage cups. In other cases, such as single-use plastic cutlery or plates, alternatives do exist but comes at a much higher price. As 90% of hospitality businesses are micro-enterprises, HOTREC considers that, while the Commission proposal goes in the right direction, it should be amended to take into consideration that economic reality without compromising the overall aim of reducing single-use plastics impact on the environment. In particular, concerning the ban on the placing on the market of single-use plastics listed in part B of the annex: the introduction of a one year derogation after the general ban when sold exclusively to professional hospitality/catering services should be considered. This would allow market forces to play their role and give enough time for prices of alternatives to go down during this extra-year of transition for this specific channel only. This would help alleviate problems faced by SMEs/micro-enterprises. Besides, Member States should be recommended to set-up transition funds to help small businesses switching to the more costly alternatives and should incentivise the production of cheaper alternatives to SUP. Finally, concerning the consumption reduction targets: HOTREC supports a reasonable deadline for achieving them of not less than 6 years after the 2 year-transposition period – as currently proposed. Further details are available in the HOTREC position paper attached.
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Meeting with Maximilian Strotmann (Cabinet of Vice-President Andrus Ansip)

9 Jul 2018 · Platforms, sharing economy

Response to Fairness in platform-to-business relations

29 Jun 2018

Please find the position of HOTREC attached.
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Response to Targeted revision of EU consumer law directives

20 Jun 2018

The fast evolving digitalisation of the economy and the transformation of consumption patterns make necessary some adjustments to the current EU consumer framework. This is particularly true in the tourism sector (the 3rd socio-economic activity in Europe) which is being radically transformed by digitalisation and the dominant market power of platforms. The Commission proposal for a better enforcement and modernisation of EU consumer protection rules represents an excellent basis to bring fairness, efficiency and responsibility to online markets. It should be supported, and can be further improved to meet fully today’s market reality. As identified in the European Commission’s impact assessment, consumers suffer important detriments when using online marketplaces because of largely un-transparent market behaviours and a lack of information provided to consumers using online marketplaces. HOTREC shares the Commission’s assessment and supports the Commission proposal to bring new transparency requirements for online marketplaces, which should even be strengthened on some aspects. In particular, HOTREC identified some arese where the Commission proposal can be further improved: • Search results driven by a remuneration shall be made transparent to consumers. In this regard, amendment to N°11 of annex I of the Unfair commercial practices Directive and the new article 6a(a) of the Consumer Rights Directive (proposed by Article 2(4) of the Commission proposal) are strongly welcome and go in the right direction. Nevertheless, the new article 6a(a) of the Consumer Rights Directive shall also specifically mention that online marketplaces shall indicate prominently and in an unambiguous manner to the consumer when there is a remuneration link between the online marketplace and the specific supplier driving the ranking. • Transparent requirements are necessary to avoid fake discounts: the new article 6a of the Consumer Rights Directive (proposed by Article 2(4) of the Commission proposal), should be completed by a new paragraph making it mandatory for online marketplaces to indicate the calculation basis of the discounts displayed for a specific product resulting from the search query of teh consumer. • Consumers must know if they contract with a trader for consumer laws to be effective: the new article 6a(b), 6a(c) and 6a(d) of the Consumer Rights Directive proposed by article 2(4) of the Commission proposal are strongly welcome to avoid consumer detriment and should be completed to ensure that information requirement about whether the third party is a trader is not only based on the declaration of the third party but also in light of the knowledge by the online marketplace of the activity of the third party on the online marketplace. • Certainty for consumers: online market places shall display the official classification of a service where appplicable. In some important consumer markets, products often benefit from an official classification/categorisation/quality grade, which is well known by consumers. Unfortunately, some online marketplaces do not inform about it, but instead ambiguously refer to alternative “non-official” (but similar) systems (without informing consumers properly). A new requirement for online marketplaces should be introduced to inform consumers about the existing classification or official quality categorisation of a product/service (where applicable). Finally, HOTREC fully supports the Commission’s proposal to remove un-necessary burdens for businesses which do not affect negatively consumer rights. The Commission proposal to amend article 7(4) of the Unfair Commercial practices Directive and article 6-1(c) of the Consumer Rights Directive are strongly welcome and will reduce red-tape without compromising consumer protection.
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Response to Revision of the Drinking Water Directive (RECAST 2017)

26 Mar 2018

The European Commission recently proposed to revise the EU Directive on the quality of water intended for human consumption with the view to improve the quality/safety of drinking water, to improve access to drinking water and to provide better information to citizens about drinking water, in order to boost its consumption. While the European hospitality sector supports the overall aim of improving water quality and access to water, HOTREC nevertheless questions why the Commission proposal intends to regulate restaurants’ offers of services and pricing policy. Indeed, recital 17 and article 13-1-c of the Commission proposal provides that in order to improve access to water intended for human consumption, Member States shall be required to “encouraging the free provision of such water in restaurants, canteens, and catering services.” This proposal should be amended, as it neglects several critical aspects of the restaurant sector: - It directly contradicts contractual freedom in a highly competitive market; - The Commission proposal does not make a distinction between clients and non-clients of a restaurant: many restaurants across Europe already provide tap-water to clients at no extra-cost, as it is considered to be part of the service paid by the client ordering a meal. However, it is unacceptable to extend such service to non-clients. - A service is never free but always entails costs (e.g. cost of the staff serving, cost of premises, use of glasses, cleaning, etc.) This should be recognised. - Paid for mineral water and non-alcoholic drinks are an important source of revenues for restaurants.An EU policy favouring the declining of their consumption would negatively impact the restaurant sector's economic long-term sustainability. This is especially true, as the hospitality sector is composed at 91% of micro-enterprises working with low margins and employing more than 10 million people. - The proposal discriminates the restaurant sector against other commercial activities (which are not targeted by the Commission proposal, despite the fact that public/clients could have access to water in these other kind of commercial premises). Recital 17 and article 13-1-c of the Commission proposal should be amended to better take into consideration these crucial aspects. HOTREC calls on the co-legislators to: - Clarify that the Directive does not make it mandatory for Member States to impose any measure on restaurants but rather to promote voluntary behaviours; - Clarify that the provisions about tap-water in restaurants concern only actual clients of the restaurants (i.e. already consuming a paying meal); - Specify that a reasonable fee covering the actual cost of the service may be charged; A more detailed analysis (with proposals to tackle the issues mentioned) is available in annex.
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Response to The future of the visa policy

15 Feb 2018

NET, the Network for the European Private Sector in Tourism, welcomes the Commission’s plans to modernize the EU visa policy, as set out in the roadmap for the Communication on the future of the visa policy published on 18 January 2018. In attachment please find all our comments to the roadmap.
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Response to Fairness in platform-to-business relations

22 Nov 2017

HOTREC thanks for the possibility to comment on the Inception Impact Assessment related to the Fairness in platform-to-business relations initiative. HOTREC, representing hotels, restaurants and cafes in Europe, welcomes the Commission’s plans to take action to balance the European Single Market regarding platform and business relationships. The Inception Impact Assessment mirrors well the main problems of concern to hospitality businesses vis-à-vis online platforms. Indeed, businesses are becoming more and more dependent on online platforms, which have become the access gate to the market, as rightly pointed out by the Commission. According to the experience so far, and taken the strong interests of the market dominant platforms, HOTREC considers that platform led voluntary action will not solve the core problems of European businesses. For little hope in this regard proves the voluntary commitment in May 2016 e.g. of the business association of the main Online Travel Agents to implement the then published Key principles for comparison tools. Unfortunately, following this commitment, nothing has been done in the past one and a half years by the platforms e.g. regarding the first and one of the most important principles, namely the identification of advertising in the default search results and to highlight paid for rankings. Taken the above into account and in order to allow for a truly reassuring and fairer market environment for the over 1,8 million hospitality businesses in Europe, HOTREC proposes the European Commission to follow the route of policy option 3, thus allowing for a more calculable and supportive business environment in the digital economy. HOTREC considers, that, as identified by the Commission, unexploited and restrained innovation capacity of businesses could only be released in a stable, reliable and truly accountable market environment which cannot be entrusted on vague and business interest motivated experimental industry-led measures. Attached is also HOTREC’s position following the Commission Communication on the Mid-Term review on the implementation of the Digital Single Market Strategy, highlighting some of the core issues for hospitality businesses and also putting forward proposals regarding a principle based legislative proposal.
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Response to Commission Reg. (EU) on the application of control & mitigation measures to reduce the presence of acrylamide in food

5 Jul 2017

HOTREC is the umbrella association representing the European hospitality industry (hotels, restaurants, cafés and similar establishments) at EU level. It is composed of 41 national hospitality associations established in 29 European countries. The EU hospitality sector is composed of more than 1.8 million businesses, which provides 10.2 million jobs. The hospitality sector is highly fragmented, as 91% of hospitality businesses are micro-enterprises (i.e. employing less than 10 persons), and more than 99% are SMEs. It is also a sector which operates on low margins overall, making it extremely sensitive to red-tape and new administrative and economic burdens. HOTREC welcomes the stakeholder consultation on the draft Commission Regulation establishing mitigation measures and benchmark levels for the reduction of the presence of acrylamide in food. HOTREC sees favourably the approach to identify appropriate mitigation measures and benchmark levels as indicators of performance instead of opting for a radical one size-fits-all approach. This will help enterprises reducing acrylamide content, while taking into consideration the specific situation of each sector and business. Nevertheless, HOTREC considers that the draft Commission text still needs further improvements on a number of provisions. 1- The delineation of the sector covered by part A and part B of Annex II (and in particular article 2-3) is not clear enough and should be fine-tuned, as the word "larger" is not defined, and as some establishments which do not produce standardised food products (but are centrally supplied for some raw ingredients) may fall inadvertently under the scope of article 2-3. 2- Concerning Part A of Annex II for French-fries: - further flexibility is needed for the choice of potato for restaurants and chefs - for further explanation, see detailed position attached. - there should be no timing indication for washing/soaking potatoes in restaurants, as it is not practical/feasible to regulate it in restaurants (impossibility to anticipate the quantity of potatoes to be washed/soaked for a specific service, impossibility to make clients wait too long after they ordered a specific product, risk of creating food waste if too much potatoes are washed/soaked in advance, etc.) - for further explanation, see detailed position attached. - blanching should not be mandatory, as it is most of the time impossible to implement it for restaurants using raw products - for further explanation, see detailed position attached. - a single (and simple) harmonised colour guide for potatoes should be adopted with the regulation and distributed freely by public authorities to SMEs in high quality format (to avoid problems linked to differences in printing quality and to fading of colours because of prolonged light exposure in restaurants kitchen) - for further explanation, see detailed position attached. 3. Concerning Part A of Annex II for bread: any reference to a colour guide for toasting sandwiches should be removed, as it is not a practical tool given the variety of types of sandwiches and white bread (which is not defined by the Regulation) that can be used for such purposes. Moreover, it is disproportionate for the very limited use this colour guide may have for retail establishments offering toasted sandwiches - for further explanation, see detailed position attached. 4. Articles 2 and 3 of the Regulation should be reversed to allow for an easier understanding of the text. 5. A longer timeline should apply for entry into force in order to give the necessary time to SMEs and micro-enterprises to adjust to the new regulatory regime. A detailed position (with concrete justifications illustrating the points mentioned above) is attached to this statement. We thank the Commission in advance for considering the arguments and proposals made by HOTREC in the attached detailed comments.
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Response to A NEW START TO SUPPORT WORK-LIFE BALANCE FOR PARENTS AND CARERS

27 Jun 2017

Please see HOTREC's position paper in the attached file below.
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Meeting with Juhan Lepassaar (Cabinet of Vice-President Andrus Ansip)

4 May 2017 · Platform-to-business relations

Meeting with Michel Servoz (Director-General Employment, Social Affairs and Inclusion)

10 Feb 2017 · Social dialogue

Meeting with Elżbieta Bieńkowska (Commissioner) and

10 Jan 2017 · Collaborative economy

Meeting with Elżbieta Bieńkowska (Commissioner)

14 Oct 2015 · Tourism sector

Meeting with Anna Herold (Digital Economy)

3 Jun 2015 · Benchmarks of Fair Practices in Online Distribution