Key takeaways

• On August 30, the Council of the European Union (EU) recommended that its member states remove the U.S. from their unrestricted travel lists.
• Each member state will decide its own restrictions, but U.S. travelers are likely to continue to be able to enter Europe if they can provide proof of Covid-19 vaccination and/or negative tests. Quarantine requirements may also return, although the first policies announced waive this requirement upon negative tests.
• The new restrictions reflect the worsening Covid-19 situation in the United States. More broadly, they capture a moment when Europe is surpassing the U.S. in vaccination rates (after trailing in the spring) and when European irritation has grown over continued U.S. restrictions against vaccinated and tested European visitors. The restrictions also come ahead of several major summits and international events taking place in Europe in the fall.
• Multiple European countries have made testing (including rapid testing) widely accessible and required for entry to restaurants, concerts, movies, or other events. A variety of “vaccine passports” are in use, for example in France and Italy, and may become more widely adopted. These policies contrast with the situation in much of the United States, and further divergence may contribute to more restrictions on travel.

New travel restrictions

On August 30, the Council of the EU updated its list of “safe” countries eligible for restriction-free travel to Europe. Amid rising Covid-19 cases due to the delta variant, the updated list no longer includes the United States, increasing travel uncertainties. However, the legal basis for the list, a Council decision from late May, is still a non-binding recommendation for member states and partner countries, and leaves avenues for travelers fully vaccinated with Pfizer, Moderna, AstraZeneca, or Johnson & Johnson vaccines from all countries to enter the bloc.

Although uncertainty about the implications of the new restrictions remains, fully vaccinated travelers from the United States will likely be able to enter Europe, albeit with stricter checks and rules. Depending on member states’ policies, vaccinated Americans may have to present a negative Covid-19 test before entering or quarantine for a brief period. Different rules may also apply to transiting passengers in some countries.

The recent decision marks a return of uneven country-by-country policies for U.S. travelers, replacing the mostly consistent approach of the “safe” country list that had removed most barriers to travel. People, businesses, and organizations planning travel and events in Europe should regularly consult embassy websites and the EU’s Reopen website. Travelers returning to the U.S. also must present a negative Covid-19 test before entering the U.S.

Geopolitical context

The new travel restrictions reflect the health situation in the U.S. and Europe. They also come against a background of European irritation over the U.S.’ refusal to open travel for vaccinated and tested Europeans, and as the summer tourist season is ending. An undercurrent of concern that the U.S. withdrawal from Afghanistan may increase migration to Europe – a core domestic issue in multiple countries – has made a tough stance towards the U.S. broadly popular. Major U.S.-Europe dialogues this fall on issues such as climate (at the UN Climate Change Conference, or COP26, in early November), Covid-19 recovery (at the G20 in late October), and technology regulation (at the first meeting of the Technology and Trade Council in late September) could reset the tone or reinforce a shift from the halcyon early days of the Biden administration.

The issue of travel reciprocity deserves special attention in the months ahead. Since March 2020, non-essential travel by Europeans to the U.S. has been banned, a policy which has separated families and hampered economic activity. When the EU’s travel ban on travelers from the United States was lifted in June 2021, EU officials noted that the measure should be met with reciprocity from the U.S., a topic which has been addressed at several high-level EU-U.S. meetings to no avail. European governments have also been responsive to #LoveIsNotTourism online movements and protests, asking for exceptions to reunite families, which the U.S. has also not reciprocated. Member state governments and the EU have noted that the U.S. ban is no longer supported by the epidemiological situations on either side of the Atlantic and that the U.S. continues to allow travelers from countries with higher rates of Covid-19 spread and lower vaccination rates. As the two sides look this fall to frame a united, democratic approach to the rise of authoritarianism, this seems like an issue on which more coordination would be both possible and popular.

Health policy in Europe

The spread of the delta variant in the U.S. may also serve as a cautionary tale on the risks of low vaccination rates and the rise of variants for European policymakers. Although the EU recently surpassed the U.S. in the percentage of people fully vaccinated, several member states remain far behind. European governments are likely to consider vaccination mandates or so-called “vaccine passports” to access public facilities, like those implemented in France and Italy. Both policies are more likely than further lockdowns, which come at high economic and political costs. ASG advises continued monitoring of policies and restrictions over the coming months as well as increased awareness about the spread of the delta variant in Europe.

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About ASG

Albright Stonebridge Group (ASG), part of Dentons Global Advisors, is the premier global strategy and commercial diplomacy firm. We help clients understand and successfully navigate the intersection of public, private, and social sectors in international markets. ASG’s worldwide team has served clients in more than 120 countries.

ASG's Europe Practice has extensive experience helping clients navigate markets across Europe. For questions or to arrange a follow-up conversation please contact Pablo Rasmussen.