The Legal Impacts of COVID-19 in the Travel, Tourism and Hospitality Industry

338 LEGAL IMPACTS OF COVID-19 IN THE TOURISM INDUSTRY Measures as well as the Consumer Protection Code26, the Travel Agencies Act27 and the General Act of Tourism28 only deem it as a general rule (objective/strict liability). The only exception is the liberal professional working as a supplier29. On the economic impact analysis provided for in the Economic Freedom Act30, this impact must have as reference the economic impact in the tourism trade as well as tourist-consumer. It is important that this analysis must have a balance between tourism trade suppliers and consumers. A point of worry is the 90-day limit from the publishing of the Provisional Measure No. 924/2020 to choose if the consumer has one of the three available options already mentioned31. Depending on the evolution of the COVID-19 crisis in Brazil, the indicated deadline may be changed a better option, especially if the purpose of the trip is non-reschedulable (academic or artistic events for example). There is an abuse in prohibiting the use of administrative sanctions listed on the Art. 56 of Consumer Protection Code, as established on Art. 5, Provisional Measure No. 948/2020. This prohibition reduces the possibility of consumer protection and may be used as a motivation to reduce the cooperation of suppliers to solve consumer problems. Additionally, it is important that the content of Provisional Measures may be altered in the federal legislative houses, thus improving the texts in order to solve these possible conflicts, instead of most of conflicts being based on the SENACON Technical Note. At least there is a bill on Emergency and Transitional Legal Regime for Private Law Legal Relations (RJET) in the period of the Coronavirus pandemic (COVID-19), not approved in the Senate32, then sent to Chamber of Deputies33 to be approved and currently waiting the Presidential approval to be an Act. The discussion of its text is proceeding and it is probable that this bill will be an Act. 26 Act No. 8078/90. 27 Act. No. 11.771/2008. 28 Act. No. 12.974/2014. 29 Art. 14, § 4, Consumer Protection Code. 30 Art. 5, Act. No. 13.874/2019. 31 Art. 2, § 1, Provisional Measure No. 924/2020. 32 Senate Bill No. 1179/2020. Available in https://www25.senado.leg.br/web/atividade/materias/- /materia/141306, accessed on 5 May 2020. 33 Chamber of Deputies Bill No. 1799/2020. Available in https://www.camara.leg.br/proposicoesWeb/fichadetramitacao?idProposicao=2247564, accessed on 5 May 2020.

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