On April 23, 2026, the European Commission issued a draft for comments on the Regulation on Sustainable Tourism Services, proposing that from 2027 onward, online travel platforms (OTAs) operating in Europe be required to disclose to consumers the Scope 1+2 carbon emissions intensity (tons CO₂e/person-day) of their partnered Chinese destination management companies, hotel management companies, and transport service providers. This move will directly affect the export capability of Chinese cultural and tourism service enterprises to Europe, and will in particular create substantial compliance pressure for service entities in the outbound tourism supply chain that bear fulfillment responsibilities. It deserves close attention from online travel platforms, international travel agencies, Chinese destination service providers, hotel management companies, and cross-border transport service providers.

Event Overview

On April 23, 2026, the European Commission officially released the draft Regulation on Sustainable Tourism Services, launching a 12-week public consultation for the public and stakeholders. Article 17 of the draft clearly states that from January 1, 2027, all online travel platforms (OTAs) providing travel booking services within the EU must prominently disclose on their product pages the Scope 1+2 greenhouse gas emissions intensity data of the Chinese destination management companies, hotel management companies, and road/air transport service providers involved in the travel products sold, measured in tons of carbon dioxide equivalent per person-day (ton CO₂e/person-day). This data must be verified by an EU-recognized third-party verification body and disclosed together with the platform’s own sustainability statement.

Which Sub-sectors Will Be Affected

Chinese destination management companies (destination ground service enterprises)

As the fulfillment entities that directly undertake orders from European OTAs and execute them on the ground, destination management companies will, for the first time, be included in the EU’s front-end carbon information disclosure chain. The impact is mainly reflected in the higher market entry threshold—if they cannot provide a Scope 1+2 carbon emissions calculation report that meets EU-recognized standards, they may be removed from the supplier whitelist of European OTAs; at the same time, carbon data will become a newly added mandatory indicator in the due diligence of European travel agencies, affecting contract renewals and quota allocation.

Chinese hotel management companies (including regional operators of chain brands)

The draft explicitly covers “hotel management companies,” meaning it is not limited to individual hotels, but also points to management output providers with cross-regional operating capabilities. The impact lies in the fact that Scope 1+2 emissions under management contracts, including energy consumption, refrigeration, catering, and employee commuting, will be traced back to the management entity rather than the property owner. This means that even if the assets are not owned by the Chinese side, as long as management is implemented by a Chinese company, it must assume data disclosure responsibilities, thereby driving the embedding of carbon accounting capabilities into the management system.

Chinese cross-border transport service providers (including charter flights, cross-border buses, and cruise shore transport operators)

Transport services are listed separately as disclosure targets, highlighting the sensitivity of their high-emission characteristics in the tourism value chain. The impact is concentrated in the availability of operational data—for example, fuel consumption records for cross-border long-distance buses, matching fuel consumption at flight-segment level with load factors for charter flights, and the electrification ratio of cruise transfer vehicles. All of these must form a verifiable, traceable, and comparable carbon intensity baseline; otherwise, it will be difficult to meet the standardized disclosure requirement of “tons CO₂e/person-day.”

Online travel platforms (OTAs) operating in Europe and European tour operators

Although they are not Chinese domestic enterprises, as the direct subjects bound by the rules, their procurement decision-making logic will undergo structural adjustment. The impact is reflected in the fact that the evaluation dimensions for Chinese suppliers will expand from price, fulfillment rate, and complaint rate to carbon intensity figures and the validity of their certifications; existing supplier review processes will need to incorporate new steps such as preliminary screening of green certification qualifications and validity review of third-party carbon data verification reports, indirectly increasing the compliance response costs and response cycle for Chinese suppliers.

What Key Points Should Relevant Enterprises or Practitioners Pay Attention To, and How Should They Respond at Present

Pay attention to subsequent official wording and transitional arrangements

The current draft is still in the consultation stage, and the final text may adjust key details such as the scope of application (for example, whether micro and small destination management companies will be exempted), the granularity of data disclosure (for example, whether weighted averages by route/season will be allowed), and the list of third-party verification bodies. Enterprises should continue to follow announcements on the official website of the European Commission and updates on supporting technical guidance from the European Committee for Standardization (CEN), so as to avoid making irreversible modifications too early based on the initial draft.

Differentiate between policy signals and the actual pace of business implementation

This provision is set to take effect in 2027, but actual implementation depends on the issuance of supporting standards and platform system upgrades. Based on current analysis, the first parties affected will be leading OTAs (such as Booking.com and Expedia) and their core Chinese suppliers; small and medium-sized European travel agencies and long-tail Chinese destination management companies may face a 12–18 month buffer period. What deserves more attention at present is the internal supplier carbon information mapping already launched by leading platforms, rather than immediately carrying out full-scale certification.

Sort out the existing foundation of energy and operational data in advance

There is no need to wait for the final version of the standards. Enterprises can immediately start internal stocktaking, including electricity/gas bills for the past 3 years, vehicle fuel ledgers, sample records of employee commuting methods, and carbon emission clauses agreed with outsourced cleaning/laundry service providers. These are the basic inputs for preparing Scope 1+2 reports. Collecting them in advance can shorten the subsequent certification cycle and reduce third-party verification costs.

Prudently choose a green certification pathway

The EU has not yet designated a single certification system, but the draft mentions “accounting based on ISO 14064-1 or GHG Protocol standards.” Observations show that those currently widely trusted in the EU market include PAS 2060 (carbon neutrality specification), EU Ecolabel, and CEN/TS 17839 (technical specification for carbon footprint accounting of tourism services). Enterprises should not blindly pursue the accumulation of multiple certifications, but should first match their own service type (for example, destination management companies should focus on Scope 1 mobile sources + Scope 2 purchased electricity, while hotel management companies should focus on Scope 2 + part of Scope 1 equipment fuel), and select 1 mainstream, scalable certification as the starting point.

Editorial Viewpoint / Industry Observation

From an industry perspective, the current draft is better understood as a strong-signal policy tool rather than a regulatory directive taking immediate effect. Its core intention is not to eliminate non-compliant Chinese suppliers in the short term, but to systematically reshape the value ranking of European tourism procurement through a consumer-end transparency mechanism—turning environmental externalities into commercial parameters that are comparable and accountable. This means that carbon data will in the future become, like business licenses and insurance certificates, a basic element of the “digital passport” for entering the European tourism supply chain. What the industry needs to keep watching is not only the final legislative text of the EU, but more importantly how leading European OTAs will translate this requirement into platform algorithm weighting, search ranking logic, and merchant rating models—changes in these back-end rules often have more practical impact than the legal text itself.

Conclusion

This draft marks that the export of Chinese cultural and tourism services is moving from traditional quality compliance into a new stage of environmental performance compliance. Its practical significance does not lie in immediately setting up barriers, but in revealing the certain direction of the green restructuring of the global tourism value chain. At present, it is more appropriate to understand it as a forward-looking capability warning: carbon footprint is no longer just an optional chapter in ESG reports, but a key operational indicator that will affect order acquisition, customer contract renewals, and channel access over the next 3–5 years. The premise of a rational response is to clarify one’s own role positioning and data responsibility boundaries in the tourism service chain, avoid broad and unfocused benchmarking, and concentrate on specific links that are verifiable, improvable, and communicable.

Source Note

Main source: the Draft Regulation on Sustainable Tourism Services published on the official website of the European Commission (public consultation draft released on April 23, 2026); items to continue monitoring: the final legislative timetable, the formal release progress of supporting accounting standards (CEN/TS 17839), and updates to the list of EU-recognized third-party verification bodies.