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Position on the European Commission's new regulation on EU Digital Covid Certificate

Thursday, 17 March 2022
press-releases Tourism

Position on the European Commission's new regulation on EU Digital Covid Certificate

70 public and private travel and tourism organisations propose several amendments to the new EU Digital COVID Certificate Regulation with the aim to secure the freedom of movement across the continent and guarantee harmonised rules when the Certificate is in use.

The European Tourism Manifesto alliance, the voice of the travel and tourism sector in Europe, welcomes the European Commission’s proposal that amends and extends the use of the EU Digital COVID Certificate (EUDCC) to facilitate free movement during and in the aftermath of the COVID-19 pandemic. The EUDCC system is a great success story as the only functioning COVID-19 certificate system operational at the global level. As a result, the EUDCC has gained increasing significance worldwide and has a crucial role in facilitating safe international travel and economic recovery. By 25 February 2022, 35 non-EU countries and territories are connected to the EUDCC system, with more expected to join in the future.

While we see the restrictions related to COVID-19 in most Member States being lifted and we are looking into the recovery of travel in Europe this summer, the role of the EUDCC remains crucial to enable the gradual restoration of extra-European tourism arrivals. We believe that a more ambitious approach is needed to fulfil and enhance the role of the EUDCC as one of the key digital solutions to restore international mobility and the de-facto global standard.

The current EUDCC Regulation and the proposal from the European Commission do not cover most of the vaccines that are currently administered around the world, including those that have completed the WHO emergency use listing procedure. Many of these vaccines have not applied (and are unlikely to do so in the future) for marketing authorisation to European Medicines Agency (EMA) or a competent Member State authority simply because the developers do not intend to put those vaccines on the EU market. In many cases, the same vaccines administered around the EU and listed by the Regulation are available under a different trade name in other countries, and therefore fall out of the scope of the EUDCC. This also applies to some of the vaccines that the EU is helping deliver under the COVAX scheme.

The limited scope of the current Regulation and its proposed amendment is also creating vaccine inequalities among EU citizens. Some Member States already administer to their citizens vaccines which are not mentioned by the Regulation.

As a result, and in an effort to enlarge the scope of the vaccines that may be used as the basis for the issuance of an EUDCC, we propose to adapt the Regulation to include all vaccines that have completed the World Health Organization (WHO) emergency use listing procedure. In addition, people who opted for a vaccine currently not on EMA or WHO list should still have a fully accepted EUDCC if they choose to receive a booster vaccination with a vaccine authorized by WHO or EMA.

In the future, it is not excluded that the epidemiological situation deteriorates, and Member States resume the use of the EUDCC or some of its components to allow access to bars, restaurants, hotels, museums, sites, concert halls, trade fair centers, and other venues. In this case, it is important that national rules mirror border and travel requirements, and that the EUDCC is implemented consistently in particular with regards to the rules for children and young adults below 18 years old. Member States are recommended to accept at national level all the vaccination certificates accepted at the border.

This would further support the recovery of the EU tourism sector and offer certainty for non-EU travellers.

Lastly, the verification of EUDCC shall not be used as a reason to impose additional restrictions to the freedom of movement such as the temporary reintroduction of controls at internal borders. Its use should be discontinued as soon as there is clear indication that the virus has reached a manageable level of transmission that does not result in severe impact on public health.

The European Tourism Manifesto alliance gathers 70 European public and private organisations, covering the whole tourism value chain and beyond. The alliance calls on the European Union for action on key policy priorities for the tourism sector. For more information, please visit

The Secretariat and Chairmanship of the alliance are currently held by the European Travel Commission (ETC). For any enquiries please contact us via
The full list of supporting organisations can be found at