Starting from 1 May 2026, under the ‘Green Digital Platform Pilot Program’, the EU will implement new carbon footprint disclosure rules for online travel platforms (OTAs) serving European consumers, requiring them to publicly disclose the carbon emissions data of the Chinese destination management companies, hotels, and transport service providers connected to their platforms. This policy directly affects Chinese B2C service providers in the outbound tourism service supply chain, including companies involved in study tour groups, chartered transport, itinerary planning, and other segments, marking a systemic elevation of low-carbon compliance thresholds for China’s tourism service exports.

Event Overview

The EU has formally notified its member states that, starting from 1 May 2026, under the framework of the ‘Green Digital Platform Pilot Program’, online travel platforms (OTAs) serving European consumers must mandatorily disclose the carbon footprint data of the Chinese destination management companies, hotels, and transport service providers connected to their platforms. Chinese suppliers that are not integrated into carbon accounting systems recognized by the EU or equivalent certification schemes will face restrictions in front-end display and search ranking priority on the platforms. This requirement covers B2C tourism service segments that directly serve European consumers, including itinerary planning, chartered transport services, and study tour groups.

Which Sub-sectors Will Be Affected

Chinese Outbound Tourism Destination Management Companies

As direct contracted service providers for EU OTA platforms, destination management companies will need to provide the platforms with verifiable carbon footprint data. The impact is reflected in the following: destination management companies unable to provide compliant carbon data may be downgraded in display priority or even removed from the platform; existing cooperation workflows will need to incorporate new steps such as carbon accounting preparation, third-party verification, and data interface integration.

Chinese Domestic Hotel and Homestay Operators Involved in Europe-related Business

All Chinese hotels selling guest rooms to European consumers through OTA platforms, including chain hotels, individual hotels, and distinctive homestays, fall within the disclosure scope. The main impacts are as follows: platforms may require them to supplement operational carbon emissions information such as energy consumption, waste treatment, and local transportation connections; small and medium-sized hotels lacking basic energy metering or without prior carbon inventory experience will face data supply bottlenecks.

Cross-border Tourism Transport Service Providers (including chartered vehicles, customized buses, airport transfers, etc.)

As high-emission segments within itineraries, such enterprises will face higher requirements for the granularity of carbon data (such as vehicle model, fuel type, driving mileage, load factor, etc.). The impact lies in the need to establish vehicle-level operational ledgers, while existing rough scheduling records will be difficult to use in meeting the traceability and third-party verification requirements needed for disclosure.

Tourism Supply Chain Technology Service Enterprises (including SaaS, booking systems, and carbon management tool providers)

Their clients are mostly the above three types of entities. The impact is reflected in rising market demand for lightweight, low-cost carbon accounting SaaS modules adapted to Chinese small and medium-sized tourism service providers; however, there is still no clear standard specifying concrete technical interface requirements, creating uncertainty in solution adaptation.

What Should Relevant Enterprises or Practitioners Focus On, and How Should They Respond at Present

Pay attention to the EU’s subsequently published mutual recognition list for certification systems and transitional arrangements

At present, only the requirement for a “certified carbon accounting system” has been made clear, but the specific accepted standards have not been listed (for example, whether China’s CCER methodology, ISO 14067, or GHG Protocol Scope 3 will be accepted). Enterprises need to continuously track the implementation rules and whitelist updates issued by the European Commission and the competent authorities of member states.

Distinguish between the pilot scope of the platform and the actual pace of business implementation

This policy belongs to a “pilot program”, and the number of platforms participating in the first batch, the countries covered, and the product lines involved have not yet been announced. Enterprises should not immediately make full-scale investments in building high-cost accounting systems, but should instead prioritize identifying the leading EU OTAs with which they already cooperate or intend to cooperate, as well as the key categories of tourism products they promote (such as study tours and ecotourism), and carry out targeted preparations.

Launch baseline carbon data mapping and build internal coordination mechanisms

It is recommended to start with the “minimum viable unit”: sort out the basic energy and transport data of typical tour groups/room nights/vehicle trips over the past 12 months (such as hotel electricity bills, vehicle refueling records, and driver schedules), while simultaneously clarifying the internally responsible departments (operations + finance + IT), and avoid simply assigning carbon-related work to administrative or marketing departments.

Carefully assess the qualifications and service boundaries of third-party verification bodies

At present, the EU has not designated a directory of verification bodies. Before engagement, enterprises need to verify whether they possess EN ISO/IEC 17065 or 17029 qualifications, and whether their verification scope covers tourism service-specific indirect emissions (Scope 3 Category 11: emissions generated from the use of products and services sold), so as to avoid being unable to meet platform verification requirements after procurement.

Editorial Viewpoint / Industry Observation

Observably, this policy is currently better understood as an institutional pilot attempt by the EU to extend its climate governance logic to digital service intermediaries, rather than a targeted regulation specifically aimed at China’s tourism industry. Its pilot nature is evident, and there remains substantial room for adjustment in terms of enforcement intensity, technical standards, and exemption clauses. Analysis shows, the real pressure does not come from disclosure itself, but from the traffic allocation mechanism platforms may implement based on carbon data—once algorithmic weighting around “low-carbon priority” is formed, it will materially reshape the visibility and customer acquisition costs of small and medium-sized Chinese service providers in the European market. From an industry perspective, this marks that export compliance for tourism services has expanded from traditional dimensions such as quality, safety, and visa requirements to the dimension of climate performance; however, at the current stage it remains at the level of signal transmission and has not yet formed a quantifiable market entry barrier.

Conclusion:
This policy is an early practice of the convergence of EU digital platform regulation and climate policy, and its industry significance lies in, for the first time, incorporating Chinese tourism service providers into the carbon information disclosure chain of overseas consumer markets. At present, it is more appropriately understood as a compliance warning and capacity-building window period—neither an immediately effective market access ban nor a technical initiative that can be ignored. The key to a rational response lies in distinguishing policy signals from business realities, completing baseline data infrastructure at controllable cost, and maintaining structured tracking of pilot developments.

Information source note:
Main source: official notification document of the European Commission (REF: C(2025) 2841 final, publication date: X month X day, 2025);
Items requiring continued observation: the list of OTAs participating in the first batch of the pilot, detailed rules for mutual recognition of certification systems, data submission format templates for Chinese suppliers, and verification procedures.