Basic orientations for the sustainability of European tourism, Brussels 21 November 2003

Brussels, 17 July 2003

European Commission
Directorate-General Enterprise
ENTR.D.3 – Tourism Unit
SC 27 2/52
B-1049 Brussels

Dear Madam, dear Sir,

Re: Basic orientations for the sustainability of European tourism

Thank you for the invitation to comment on the consultation document “Basic orientations for the sustainability of European tourism”. We disseminated the document in the different Community languages to all European trade union federations representing tourism workers.

Please note that the following comments integrate the points of view of the European Federation of Food, Agriculture and Tourism Trade Unions (EFFAT), representing workers in the hotel, restaurant and catering sectors, and of the European Trade Union Liaison Committee on Tourism (ETLC), the cooperation platform between EFFAT, the European Transport Workers’ Federation (ETF), UNI-Europa and their international federations IUF, ITF and UNI, representing employees in the various tourism sub-sectors.

Chapter II

In general, we agree with the analysis of the main challenges for the sustainability of the European tourism sector as undertaken in this chapter.

Points of disagreement are:

Under “Good public and private governance” (page 6 of the English version) you promote multi-partnership solutions, and subsume trade unions under “other interest groups”. This totally neglects the fact that in most European countries employers’ associations and trade unions, as democratically legitimated representatives of those who through their investments and through their work make tourism viable, cooperate closely and negotiate many framework conditions for the sector.

Instead of mainly encouraging vaguely binding multi-stakeholder initiatives, civil society involvement, etc., the Commission should lay more emphasis on the role of the social partners, in accordance with the EU Treaty which requires that social dialogue be promoted and additional powers given to the social partners.
This negligence is repeated in other parts of the document, and we will comment on it in the respective chapters.

Under “Sustainable supply chain“ (page 8 of the English version) we see a contradiction, when on the one hand the document states that the sector “needs to internalise socio-economic and environmental cost to get its prices right”, and on the other hand it proposes that the sector “requires de-linking economic profit from social and environmental cost”.
We believe that on the long run, tourism can only be sustainable if the sector internalises these costs. Therefore, we also have to get out of the vicious circle of “cheap bargain’ tourism. New approaches must be taken to get the message across to tourists that socially responsible and environmentally sustainable tourism has its price.

We fully agree that the sector’s enterprises should implement the concept of Corporate Social Responsibility (CSR). Actually, EFFAT started discussions with HOTREC on the joint elaboration of a Code of Conduct on CSR for the European hospitality sector.
When encouraging Corporate Social Responsibility, it should be stated clearly that any initiative has to be planned, carried out and assessed jointly by managements and workers’ representatives and trade unions in order to avoid that CSR is used by companies as a mere marketing tool, which unfortunately is the reality in many cases.

In the same paragraph the expression “adequate employment” is much too vague. What we should pursue are good, quality jobs for qualified and motivated staff that provides high-quality tourism services.

Under “Sustainable destination development” the document mentions that “community well-being in tourist destinations” is required as a pattern of sustainable destination development. The document could be more explicit in stating that profits have to be shared in a well-balanced way between the companies in the countries of origin and the tourism destinations.

Chapter III-1

In the introduction of Chapter III the document lists a number of stakeholders that “need to contribute to the realisation of sustainable tourism objectives”: tourists, SME and corporate enterprises, destinations, public administrations, and residents (page 9 of the English version). Tourism workers and trade unions should be added to this list, as they are playing a key role in the implementation of any initiative aimed at making tourism more sustainable.

Trade unions are involved in many of the initiatives you mention under III-1, but they are also actively pursuing sustainability in tourism in their daily work, e.g. in collective bargaining, in networks at various levels, and in projects such as the “Bourse Européenne Emploi Formation du Tourisme (BEEFT): Des Itinéraires pour les Saisonniers du Tourisme” (for details:, or the “Ethos Project: A network for the promotion of social responsibility in hotel and catering companies” (for details: ).

Chapter III-2

As a lot of abuse has to be noticed in the tourism sector with regard to the free movement and the posting of workers, we do not agree that there is an interest “to liberalise the tourism sector as fully as possible in the framework of World Trade Organisation-GATS” (see “Global responsibility” on page 11 of the English version). The impact of liberalisation achieved so far on the tourism sector, and in particular on employment and employment conditions, should be assessed before further liberalisation is pursued. A general rule should be: if services are provided in another country, the posted workers should benefit at least from the labour standards and working conditions applicable in the country.

The document states that a substantial reduction of remaining restrictions to trade in this sector should be achieved “without affecting the quality of service, protection of consumers, or public safety”. Here the protection of workers has to be added to the list. In general, the protection of workers’ rights and the respect of labour laws and collective agreements have to be guara The document states that a substantial reduction of remaining restrictions to trade in this sector should be achieved “without affecting the quality of service, protection of consumers, or public safety”. Here the protection of workers has to be added to the list. In general, the protection of workers’ rights and the respect of labour laws and collective agreements have to be guaranteed when services are provided at a cross-border level, they hence have to play a more prominent role in the GATS negotiations.

Chapter IV

First of all, we believe that a genuine consultation paper should be neutral when presenting and asking opinions on several options. So, saying that options A and B “should be ruled out” and option D “could be considered as the right pathway to sustainability of European tourism” (page 14 of the English version) is much too biased.

We are still very much in favour of a genuine Community policy in the field of tourism, and we recently even lobbied for getting tourism taken up in the new European Constitution. But given the fact that this option does obviously not get the necessary support, we agree that we need a more realistic approach.

Nevertheless, the Commission should play a much more active role when reinforcing the existing framework for action. Instead of predominantly listening to the lobbying of the tourism industry, which basically aims at a maximum of deregulation and liberalisation (and here we explicitly exclude trade unions from the “tourism industry”!), the Commission could send a clear signal by encouraging both sides of the industry to find common solutions to existing problems.
Just one example: After the terrorist attacks of 11 September 2001 and the following downturn of tourism, the Commission convened a meeting with the tourism industry and all concerned Commission services, and was mainly faced with demands for support and subsidies by representatives from the industry. The ILO convened an ad hoc meeting of employers’ associations and trade unions aimed at finding common solutions to the impact of the crisis on employment.

Chapter V-1

We generally agree that the “implementation should be based above all on the initiative of directly responsible and specialised stakeholders”. But this only makes sense, if tourism workers and trade unions are included in the “tourism industry” said to have the “prime responsibility” (page 15 of the English version).

We suggest to add an additional hyphen under the third bullet-point “promoting and practising the principles of European governance, through”:
- encouraging both sides of the industry to cooperate and to find joint approaches for the different tourism sub-sectors or beyond

In the text of the forth bullet-point “helping national, regional and local private and public stakeholders to assume their responsibilities …”, we suggest to insert “European” before “national”.

Chapter V-2

For the “development of user-friendly sustainability reporting mechanisms for enterprises, public administrations and funding institutions” (page 16 of the English version), the same considerations have to be taken into account as for CSR: if social criteria are neglected and workers/trade unions are not involved in the planning, implementation and monitoring of such reporting mechanisms, we risk that they could be pure marketing tools.

Chapter V-3

In general, the measures should be more precise and targeted.

Measure 2:
We agree that sustainable entrepreneurship and competitiveness, and sustainable employment and skilled workforce are particular challenges to the tourism sector, but it is not clear what this rather vague and inactive action plan could do.

Measure 3:
Why loose time to conclude an agreement with WTO, just cooperate!

Measure 4:
We do not agree that a “European Multi-Stakeholder Monitoring and Steering Group for Tourism Sustainability” (EMSMSGTS?!) “should be led by the European tourism industry, in cooperation with …”. If such a group was created, the Commission would have to lead its activities. In any case, many questions remain open: How would such a group be composed? How would it be guaranteed that the views and concerns of all interest groups are taken into account? How would decisions be taken?

Measure 5:
Here again, the document leaves the pure consultation on proposals. In the description of Measure 5 the document states “The Commission could launch …”, “This initiative could focus on …” (page 18 of the English version), but then in the second paragraph says “… The Commission is launching …”, “After the current preparatory phase …”.

Regardless whether initiatives have been started or not, it has to be ensured that trade unions are involved in a potential Round Table of stakeholders on seasonality as well as in the Multi-Stakeholder European Targeted Action on sustainable tourism transport.
If the Conference on Transport and Tourism held in Crete in May 2003 is considered as part of the “current preparatory phase”, this was a bad start in this respect, as no organisation representing the interests of transport workers was invited to the meeting.
The numerous examples how trade unions pursue to mitigate negative effects of the seasonal character of European tourism, e.g. through collective bargaining, by participating in projects such as BEEFT (see above Chapter III-1), are worth to be taken up in the proposed round table on seasonality.

Measure 6:
Same remarks as on Chapter V-2.

Chapter V-4

We do not agree with putting trade unions under “Other civil society members” (page 22 of the English version).
Most of the activities the document attributes to trade unions are subject to negotiations between them and employers’ associations and companies. A much more prominent role in the implementation of sustainable tourism in Europe should be given to social dialogue (see also remarks on Chapter IV).

Overall, the position papers on sustainability and tourism submitted by EFFAT and ETLC in October / November 2002 summarise our main concerns and should be taken into consideration (see attached).

With kind regards,

Kerstin HOWALD

EFFAT Tourism Sector Secretary
ETLC Coordinator

Rue Fossé aux Loups 38
BE – 1000 Bruxelles
Tel: ++32 2 218 77 30
Tel: ++32 2 209 62 64 (direct)
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Fax: ++32 2 218 30 18