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HOTREC reply - Public COnsultation on VBER

Thursday, 04 March 2021
working-documents online-distribution position-paper competition

The European Commission launched a public consultation on the revision of the Vertical Block Exemption Regulation (VBER) and accompanying Vertical Guidelines. This consultation is part of the on-going review process which was initiated in October 2018 with a view to having revised rules in place when the current rules expire in May 2022. An information note on this consultation is available on our website: EU competition rules – Public Consultation on the Vertical Block Exemption Regulation - HOTREC. The deadline to reply to the public consultation is 26 March 2021.

More information about the review process can be found  here

The revision of the VBER represents a major opportunity to request the European Commission to put an end to price parity clauses imposed by OTAs on hoteliers. It is also an opportunity to raise our sector’s concerns regarding brand-bidding, market structure issues and clarifying the role of agents in the OTA market.  

It should also be noted that the VBER is an essential piece of legislation for the retail sector, covering a much broader scope of topics than price parity clauses. As such, the European Commission’s public consultation document extensively covers the issues of dual distribution systems, active sales restrictions and indirect restrictions on online sales. HOTREC’s reply focuses on the section on parity obligations, as respondents are strongly encouraged not to reply to questions on which they have no particular knowledge, experience or opinion.

Therefore please find below:

  • Full HOTREC reply provided to the European Commission, reflecting the exact structure of the Commission consultation document.
  • Addenda on Brewery Contracts

Word document final HOTREC reply: