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UNI Europa recently replied to the consultation: “Regulatory and Administrative Framework on Tourism Businesses, Public Administrations, and other Tourism Stakeholders in the EU". In the aforementioned consultation, the EU Commission invites stakeholders to complain about legislation and regulation that are key in protecting workers’ rights.

This consultation on the regulatory and administrative burdens in tourism is clearly embedded in the Smart Regulation agenda. Slowly but surely, under the false pretext of regulatory and administrative burden reductions, the EU Commission is challenging the social acquis.

The consultation deliberately issues key areas of European legislation and regulation for companies to complain about. This is simply unacceptable. The consultation provides businesses, public administrations, and stakeholders the opportunity to complain about the burden of legislation and regulation on a vast array of topics, not necessarily linked to the tourism sector. Legislative and regulatory topics covered apply in the majority of cases to all sectors of the economy.

Stakeholders are invited to tick boxes without the obligation to justify their choice. All response options proposed are negative towards specific legislation (too costly, unnecessary, too restrictive, too complex, lacks transparency). The category “lacks protection” is unclear and the provided explanations are not informative. The initial aims of a legislation or regulation are totally neglected.

The Commission proposes respondents complain about health and safety at work, the organisation of working time, social security and taxation, work contracts, and rules related to unemployment. It has become a recurrent scheme in open consultations to attack health and safety at work and working time as constituting red tape for businesses.

UNI Europa expressed its serious doubts about the methodological founding of this consultation. Its design steers its outcome. The various regulations the public are invited to comment upon are extremely imprecise. It is doubtful that respondents would be able to identify the level and responsibilities assigned to each level for their complaints.

UNI Europa finds it unacceptable that this consultation is negatively oriented towards regulatory and legislative burdens. It is unacceptable that the consultation is designed in such a way that it drives the outcomes in a specific direction through an unjustified pre-selection of legislation and regulations. The consultation allows the respondent to qualify selected legislative and regulatory acts as burdensome only, without evaluating the selected acts form the onset or at least informing the respondent over what burdens are actually referred to.

UNI Europa did not support such a one-sided and restrained approach focusing on the burdens of legislation/regulation without even proposing an assessment of the benefits brought to society by a given regulation or legislation.

UNI Europa called on the Commission to stop issuing consultations that are not designed to identify problems in a certain sector. They cannot form the basis for developing concrete regulatory and legislative European initiatives nor assessing their implementation. Such consultations underpin calls for further deregulation.

The European Trade Union Liaison Committee (ETLC) comprising EFFAT, UNI Europa, ETF, IUF, UNI Global Union, and ITF submitted two contributions in this consultation process. The first expresses the general disapproval of the approach chosen by the EU Commission in the consultation over regulatory and administrative frameworks in the tourism sector. The ETLC also submitted specific replies to each relevant consultation topic highlighting the benefits and added value of specific legislation and regulations in the tourism sector.

The UNI Europa reply as well as the two submitted ETLC contributions can be accessed below.