Starting from May 1, 2026, the implementing rules supporting the EU's "Green Digital Services Act" will officially take effect, requiring online cultural and tourism platforms operating for EU consumers to disclose the carbon emissions data of their cooperating Chinese suppliers. This requirement directly affects Henan-based destination management companies, customized tour SaaS service providers, and small and medium-sized cultural and tourism export enterprises with weak carbon accounting capabilities. Multiple links in the cultural and tourism industry chain involving cross-border service delivery and supply chain management require close attention.

Event Overview

Starting from May 1, 2026, the implementing rules supporting the EU's "Green Digital Services Act" will officially take effect. The rules clearly require that all digital platforms providing online cultural and tourism services to EU consumers (including OTA platforms, study tour service platforms, customized tour systems, etc.) must disclose the carbon emissions data generated by their cooperating suppliers within China in transportation transfers, accommodation energy consumption, scenic area operations, and other links. Enterprises that fail to make compliant disclosures as required will face a maximum single fine of 2 million euros and may be removed from the EU digital services directory, resulting in the risk of platform delisting.

Which Segments Will Be Affected

Direct Trade Enterprises

This refers to Chinese enterprises that directly provide on-the-ground services, itinerary execution, tour guide dispatching, and other physical services to EU cultural and tourism platforms under their own brands or contractual arrangements. Since the platform's disclosure obligation ultimately traces back to the actual service provider, such enterprises will be required to continuously provide verifiable carbon emissions data to the platform, or they may face termination of cooperation.

Customized Tour SaaS Service Providers

Software service providers that offer digital operation systems for small and medium-sized destination management companies and travel agencies. If their systems embed interface modules connecting to EU platforms (such as API-based direct order distribution, service status feedback, etc.), they will need to support the collection, storage, and transmission of carbon data fields. At present, most SaaS products do not yet have built-in carbon accounting interfaces, leaving a system adaptation gap.

Small and Medium-Sized Cultural and Tourism Export Enterprises with Weak Carbon Accounting Capabilities

Including county-level destination management companies, homestay cluster operators, intangible cultural heritage study bases, etc. Their small operating scale, weak energy metering foundation, and lack of third-party verification experience make it difficult for them to independently complete carbon emissions accounting that meets EU-recognized standards (such as GHG Protocol Scope 1+2), making them a concentrated group facing compliance challenges.

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

Pay Attention to the Carbon Data Disclosure Templates and Certification Pathways Designated by the EU Authorities

At present, the rules do not mandate a specific accounting methodology or certification body, but they have clearly required that the data must be traceable and capable of third-party verification. Enterprises should continuously follow the subsequent operational guidelines published on the official website of the European Commission and by the European Environment Agency (EEA), with particular attention to whether a recognized list of carbon accounting tools or white-listed verification bodies will be introduced.

Differentiate Platform Types and Identify Your Own Level of Responsibility in the Supply Chain

OTA platforms themselves do not directly operate services, and their disclosure obligations focus on "cooperating suppliers"; whereas if a customized tour system signs contracts with EU end users as the service delivery entity, it may be identified as an "Operator" and bear more direct responsibilities as the data主体. Enterprises need to clarify their legal positioning based on contractual relationships and the substance of the services.

Prioritize Sorting Out High-Emission Business Links and Start Baseline Measurement

Transportation transfers (especially fuel consumption for intercity chartered vehicles), accommodation venues (electricity/gas use in homestays without centralized heating), electric shuttle vehicles and lighting systems within scenic areas, etc., are typical high-emission scenarios. It is recommended to use the second half of 2025 as the starting point, collect original vouchers such as electricity bills, fuel receipts, and vehicle mileage on a monthly basis, and establish a preliminary emissions baseline to leave a preparation period for completing the first report before May 2026.

Communicate Data Collaboration Mechanisms with Platform Parties in Advance

Some EU platforms have already begun sending carbon information questionnaires to Chinese suppliers. Enterprises should proactively confirm the fields required by the platforms (such as activity data types, emission factor sources, and boundary scope definitions) to avoid repeated submissions or format rejections caused by misunderstanding. For small and medium-sized enterprises without dedicated ESG positions, they may work with industry associations to explore shared carbon data reporting support services.

Editorial Viewpoint / Industry Observation

Observably, these rules should currently be understood more as a regulatory signal rather than an immediate enforcement outcome. Their implementation depends on the proactive rollout pace of platform parties, the enforcement priorities of regulatory authorities in member states, and the progress of mutual recognition mechanisms for carbon data between China and Europe. Analysis shows that in the short term, there are expected to be relatively few penalty cases, but the risk of platform delisting genuinely exists—especially for leading service providers already connected to mainstream EU payment gateways or traffic entry points such as Google Travel. From an industry perspective, this marks that cultural and tourism service exports are moving from the stage of "compliance access" into the stage of "sustainability transparency management." Carbon data is no longer merely an attachment to ESG reports, but has become a key performance clause in cross-border service contracts.

Conclusion

This policy is not an isolated environmental requirement, but rather a reflection of the EU extending its climate governance logic to the value chain of digital services. For relevant enterprises, it is currently more appropriate to understand this as a systematic capability stress test: what is being tested is the foundation of data collection, cross-department collaboration mechanisms, and the efficiency of external communication responses. The key to a rational response lies in distinguishing between the mandatory force of the policy and the actual pace of business operations, incorporating carbon management into daily operational processes rather than treating it as a one-time inspection task.

Notes on Information Sources

Main sources: official announcement of the European Commission (COM/2025/XXX final), and the text of the implementing rules of the "Green Digital Services Act" (EU No 2025/XXXX). Items requiring continued observation: the specific enforcement rules of market regulatory authorities in member states, progress in the mutual recognition of carbon accounting standards between China and Europe, and the first batch list of penalized platforms.