Effective 1 May 2026, the EU will pilot the implementation of the "Directive on Sustainability Disclosure for Digital Tourism Platforms," requiring online tourism platforms serving EU consumers (including OTAs, customized tour platforms, and B2B distribution systems) to prominently disclose on product pages the Scope 1+2 carbon emissions data of their partnered Chinese cultural and tourism suppliers, together with third-party verification statements. The compliance eligibility of export-oriented cultural and tourism service entities such as Henan destination management companies, study tour bases, and intangible cultural heritage workshops will be directly affected by this disclosure requirement. This policy marks the formal entry of Chinese cultural and tourism service exports into a regulatory stage of carbon information transparency, and relevant enterprises need to systematically assess their supply chain carbon management capabilities.

Event Overview

Starting from 1 May 2026, the EU will officially pilot the implementation of the "Directive on Sustainability Disclosure for Digital Tourism Platforms." The directive clearly requires that all online tourism platforms providing services to EU consumers, regardless of whether they are registered within the EU, must prominently disclose on their product pages the Scope 1 (direct emissions) and Scope 2 (indirect emissions generated from purchased electricity, steam, cooling, and heating) carbon emissions data related to cooperation projects with Chinese cultural and tourism suppliers, and simultaneously display verification statements issued by recognized third-party institutions. The currently available public information does not yet cover details such as transitional arrangements, exemption conditions, or specific lists of verification bodies.

Which Sub-sectors Will Be Affected

Direct Trade Enterprises

This refers to business entities that directly supply cultural and tourism products such as destination services, study tour programs, and intangible cultural heritage experiences to overseas OTAs and customized tour platforms under their own brands or as contracted parties. As the contractual party and responsible entity for carbon data, such enterprises will be required by platform operators to provide verifiable Scope 1+2 carbon emissions reports. The impact is mainly reflected in the fact that failure to provide compliant carbon data may lead to product delisting, termination of cooperation, or contract repricing.

Channel Distribution Enterprises

These include B2B distributors, consortium operators, and multi-tier agency organizations that provide localized fulfillment services for overseas platforms. Their business models rely on integrating resources from multiple small and medium-sized destination management companies, study tour bases, and similar suppliers. The new regulation will force them to establish upstream supplier carbon data collection and preliminary review mechanisms; otherwise, they will face the risk of delivering incomplete/unreliable data to platforms, thereby weakening channel credibility and settlement efficiency.

Supply Chain Service Enterprises

These cover third-party institutions providing professional services to cultural and tourism enterprises, such as carbon accounting consulting, energy audits, ISO 14064 certification guidance, and MRV (monitoring, reporting, and verification) support. For the first time, the directive incorporates carbon data verification into the mandatory process for cultural and tourism service exports, which will expand their business reach among small and medium-sized cultural and tourism service providers; however, service capability fit (such as familiarity with the energy consumption characteristics of cultural and tourism business formats) will become a key differentiator.

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

Pay Attention to Subsequent Official Statements or Policy Changes

At present, only the name of the directive, its effective date, and the basic disclosure obligations have been confirmed. Detailed implementation rules, lists of recognized verification bodies, data template formats, and penalty mechanisms have not yet been released. Enterprises should continue to monitor the official website of the European Commission and guidance issued by the European Environment Agency (EEA), so as to avoid making investments based on information from non-authoritative channels.

Focus on Changes in Key Business Links

The carbon data disclosure obligation applies to the "product page," that is, the smallest saleable unit such as a specific route, course, or workshop experience. Enterprises need to identify the physical sites corresponding to their high-frequency export products (for example, a study tour base where 80% of annual orders come from German platforms) and prioritize Scope 1+2 emissions inventories for those sites, rather than broadly covering all operating locations.

Distinguish Policy Signals from Actual Business Implementation

The directive is in a pilot implementation phase, and the first-year coverage scope, inspection ratio, and enforcement intensity are still unclear. At present, enterprises are better advised to treat compliance preparation as a precondition for client access rather than immediately making comprehensive investments in restructuring carbon management systems; they may first complete carbon inventories and basic verification for single-point demonstration projects to accumulate practical experience and cost awareness.

Prepare in Advance for Data Coordination and Communication Contingencies

Most small and medium-sized destination management companies and intangible cultural heritage workshops lack independent carbon accounting capabilities. It is recommended to proactively communicate with long-term partner OTAs or B2B platforms regarding data requirement criteria, timelines, and collaboration methods (such as whether joint submission is accepted and whether phased submission is allowed), while also sorting out the current archiving status of internal energy bills, vehicle fuel usage records, purchased electricity vouchers, and other original materials in order to identify data gaps.

Editorial Viewpoint / Industry Observation

Clearly, the directive currently looks more like an institutional signal than a routine regulatory norm backed by mature enforcement outcomes. Its pilot nature means there is still flexibility in execution, but the direction is clear: cultural and tourism service exports are extending from quality and safety dimensions into the dimension of climate responsibility. Analysis shows that this is not an isolated policy, but rather an extended attempt to apply the logic of the EU CBAM (Carbon Border Adjustment Mechanism) to the field of trade in services, and it may in the future spread to other export scenarios involving high-contact services. From an industry perspective, what truly requires sustained attention is not "whether disclosure is required," but "whether the data required for disclosure can be generated and verified in a stable, reliable, and low-cost manner"—this will materially reshape the compliance cost structure and competitive barriers of Chinese cultural and tourism service exports.

Conclusion:
This directive marks the entry of China's cultural and tourism service export compliance system into a new stage of explicit carbon information disclosure. Its core significance does not lie in immediately triggering large-scale market exits or rectifications, but in establishing "carbon footprint traceability" as one of the fundamental prerequisites for access to the EU market. At present, it is more appropriate to understand it as a trigger point for gradual capability building: enterprises do not need to hastily benchmark and upgrade entire systems to international standards, but they do need to start baseline carbon data mapping and verification pathway testing in real business scenarios, so as to reserve a response window for subsequent normalized disclosure.

Information Source Notes:
Main source: Official announcement of the European Commission (the legislative draft of the "Directive on Sustainability Disclosure for Digital Tourism Platforms" issued in 2025 and the notice of its entry into force).
Items pending continued observation: the release timing of implementation rules, the first batch list of recognized verification bodies, the list of pilot platforms, and the first-year enforcement assessment mechanism.