Australia was removed from the European Council's "white list", which recommends non-essential travel be barred after soaring Omicron infections in the country.
Australia was on the original list of 12 countries but was removed along with Canada and Argentina when the list was reviewed a fortnight ago.
But Dr Pulch says the list is continually reviewed every two weeks and restrictions remain flexible.
"This list is revisited so there is an opportunity for Australia, once the infection rates do come down, to be readmitted to that list," he told the ABC.
He said there was flexibility in the system including individual European nations having their own lists.
Some member countries like Italy and Greece have not moved to further restrict Australian travellers and Germany still allows quarantine-free travel for the fully vaccinated who return a negative test result.
The European Union is also reviewing whether to change the definition of fully vaccinated to three doses, with Dr Pulch saying evidence was pointing to a booster shot being needed to protect against Omicron.
"It's increasingly clear that only a booster jab gives you the safety that in the former Delta period double vaccination would've given you," he said.
"That's why we are looking at whether or not we need to redefine 'fully vaccinated'."
Restrictions for the unvaccinated are in place - but differ - across EU member states, with Spain only considering a vaccination certificate valid for 270 days after the last vaccine dose as of February 1.