BEUC position paper on the Digital Green Certificate

The COVID19 crisis has significantly impacted free movement across the EU. As the vaccination is being rolled out in all Member States, it is therefore important to adopt measures that aim at re-opening internal borders in the EU and facilitate the exercise of the freedom to circulate whilst containing the spread of the virus.

The Commission’s proposal for a Digital Green Certificate (DGC) aims at introducing a framework for the issuance, verification and acceptance of interoperable certificates on COVID-19 vaccination, testing and recovery in order to
facilitate the exercise of citizens’ right to free movement in the EU.

From a consumer perspective the following recommendations apply:

• The DGC should provide updated information of the requirements to enter or pass through each Member State. This is the only way to ensure consumers get the information they need to exercise their right to move within the EU.

• Consumers should be informed about which COVID19 tests qualify for a certificate. To this end, the European Commission should establish a list of recognised tests.

• Member States should agree on which tests are required for travelling to avoid diverging solutions undermining the right to free movement.

• As long as vaccination is not accessible to the entire population, testing must be made available free of charge.

• The principle of non-discrimination needs to be reinforced.

• The rules on data protection could be strengthened by explicitly stating that the personal data contained in the certificates shall only be processed for the purpose of accessing and verifying the information included in them.

• It should be clarified how the DGC will interplay with Passenger Locator Forms.