On April 24, 2026, the European Commission released the draft Regulation on Digital Labels for Sustainable Tourism Services, proposing that from 2027 onward, tourism platforms operating in Europe (such as TUI and DER Touristik) be required to mandatorily disclose on their product pages the carbon emission intensity of their partner Chinese destination management companies (unit: kgCO₂e/人天), with the data to be certified under ISO 14067. This move is directly related to the ability of China’s cultural and tourism supply chain to expand overseas, and in particular creates substantive compliance pressure on destination services, low-carbon transport, green hotel partnerships, and carbon accounting capabilities. Destination service enterprises in places such as Henan need to respond in advance.

Event Overview

On April 24, 2026, the European Commission officially released the draft Regulation on Digital Labels for Sustainable Tourism Services. The draft makes it clear that all digital platforms providing travel booking and itinerary services within the EU, if their products involve destination management company services within China (including transport, accommodation, guided tours, and other segments), must from January 1, 2027 disclose in a prominent position on the corresponding tourism product pages the carbon emission intensity data of that destination management company, expressed in kilograms of carbon dioxide equivalent per person per day (kgCO₂e/人天). The relevant data must be certified by a qualified third-party institution in accordance with the ISO 14067 standard. The draft is currently in the public consultation stage and has not yet formally taken legislative effect.

Which sub-sectors will be affected

Chinese destination service enterprises

Destination management companies are the core entities in the tourism service chain that directly undertake orders from overseas platforms and organize the local implementation of resources. The draft requires their carbon emission data to be mandatorily disclosed by platforms, meaning their environmental performance will be directly exposed to end consumers and procurement-side evaluation systems. The impact is mainly reflected in tighter market access qualifications—if they cannot provide compliant carbon data, they may be delisted or downgraded by mainstream European platforms; at the same time, this will force them to restructure their service portfolios, for example by phasing out high-emission vehicle use, shifting to new energy fleets, or re-screening partner hotels.

Domestic new energy tourism transport service providers

Within the carbon emission intensity of destination management companies, ground transportation usually accounts for the highest share. After the draft is implemented, destination service solutions using fuel-powered coaches will face greater pressure from carbon cost disclosure, thereby indirectly enhancing the market pricing power of low-carbon transport such as new energy minibuses and electric business vehicles. The impact is reflected in changes to order structure—platforms may give priority recommendations or weighted display to destination service solutions equipped with certified low-carbon transport capacity.

Low-carbon certification and carbon accounting service institutions

The draft explicitly requires the data to be certified under ISO 14067, which means demand will increase for third-party institutions that have experience in carbon accounting for tourism service scenarios and are familiar with the actual operation of China’s cultural and tourism sector (such as charter mileage statistical methods and hotel energy consumption conversion logic). The impact is concentrated in the front-loading of service demand—destination service enterprises need to launch accounting system construction and initial certification within 2026, rather than waiting to respond after the policy is implemented.

Domestic supplier management teams of tourism platforms

If large domestic OTAs or B2B tourism distribution platforms supply China destination resources to European platforms, their supplier audit processes will add new carbon data compliance items. The impact lies in internal management upgrades—it will be necessary to establish carbon files for destination management companies, set access thresholds, coordinate certification progress, and may also drive upstream suppliers to jointly build carbon accounting capabilities.

What key points should relevant enterprises or practitioners pay attention to, and how should they respond at present

Pay attention to subsequent revision milestones of the draft and transition period arrangements

The current draft is still in the consultation period, and key details such as the final effective date, exemption clauses (such as applicability to micro and small destination management companies), and the approved list of certification bodies have not yet been clarified. Enterprises should continuously monitor updates on the European Commission’s official website and the Official Journal of the European Union (OJEU), with particular attention to the feedback summary and revision notes before the third quarter of 2026.

Prioritize sorting out baseline carbon emission data for core export routes

Taking Henan as an example, if the Zhengzhou–Luoyang–Kaifeng cultural route is a key promoted product, the enterprise should immediately compile operational parameters from the past three years for typical group types on this route, including vehicle types and mileage, partner hotel room types and length of stay, and scenic area shuttle modes, in order to form a preliminary carbon emission estimation model. This step does not depend on certification, but it can support efficient follow-up coordination with certification bodies and identify priority emission reduction scenarios (such as replacing a certain fuel-powered shuttle segment with an electric minibus).

Launch ISO 14067 certification pathway evaluation and partner selection

Certification is not a one-time action; it needs to match the actual operational granularity of the enterprise. Enterprises should assess their own data collection capabilities (for example, whether vehicle fuel consumption can be recorded by tour group and whether hotels can provide itemized energy consumption bills), and compare and select certification bodies that are recognized by the EU and have experience in China cultural and tourism projects. Avoid choosing general institutions that are only skilled in industrial manufacturing or the power sector, so as to prevent deviations in the definition of accounting boundaries.

Simultaneously optimize supply chain coordination mechanisms

Carbon data is not generated in isolation; it requires hotels, fleets, scenic areas, and other parties to cooperate in providing original supporting documents. Enterprises should communicate the direction of the draft with core partners immediately, negotiate the scope of data sharing and division of responsibilities (for example, hotels are responsible for providing annual electricity consumption data, while destination management companies are responsible for calculating vehicle mileage), and avoid certification delays caused by breakdowns in coordination near the compliance deadline.

Editorial viewpoint / industry observation

From an industry perspective, the current draft is more appropriately understood as an institutional preparatory measure carrying a strong binding signal, rather than a trade barrier taking immediate effect. Its core value does not lie in whether it will be implemented as scheduled in 2027, but in the fact that it marks the EU’s move to bring tourism services into the main track of climate governance, and for the first time includes Chinese operators at the end of the supply chain within a quantifiable, traceable, and comparable carbon performance framework. From an analytical perspective, this is not an isolated policy, but one that is in line with discussions on the expansion of the EU CBAM and the upgrading of service trade rules under the Green Deal. What deserves more attention at present is that it is accelerating the reshaping of the “compliance discourse power” structure in China-EU tourism cooperation—in the past, service standards were led by platforms, while in the future carbon performance will become a fundamental access dimension alongside price and quality.

Conclusion

In essence, this draft is a systemic compliance rehearsal aimed at the execution level of China’s cultural and tourism sector. It does not change the nature of tourism services, but it redefines the technical connotation of a “reliable service provider.” For the industry, the present period is better understood as a clearly time-bound window for capability building: whether carbon data can become traceable, certifiable, and collaborative within 2026 will directly determine visibility and competitiveness in mainstream European channels from 2027 onward. The key to a rational response lies in transforming carbon requirements from “external regulatory pressure” into an “internal operational microscope,” thereby taking the opportunity to clarify the real cost structure and the room for green improvement.

Information source note

Main source: the original text of the draft Regulation on Digital Labels for Sustainable Tourism Services published on the official website of the European Commission (public version released on April 24, 2026).

Items requiring continued observation: the final legislative text of the draft, effective date, transition period arrangements, mutual recognition list of ISO 14067 certification bodies, applicability clauses for small and medium-sized enterprises, and other matters still need to be tracked through subsequent official EU notices.