Green Claims Compliance for Hotels

The EmpCo Directive is Directive (EU) 2024/825, the Empowering Consumers for the Green Transition Directive, which amends EU consumer and unfair-competition law to regulate environmental claims in advertising. It applies across the European Union from 27 September 2026 and covers hotels like any other business communicating with consumers — on websites, booking platforms, printed materials and on-site signage.

Hotels can no longer use generic environmental claims such as “sustainable hotel”, “eco”, “green” or “climate friendly” unless recognised excellent environmental performance is demonstrated. Also prohibited: climate-neutrality claims based on offsetting outside the value chain, self-designed sustainability badges without independent verification, whole-property claims derived from one isolated measure, and presenting a legal requirement as a special achievement.

A hotel cannot claim climate neutrality on the basis of purchased offsets alone — the EmpCo Directive prohibits claims of neutral, reduced or positive environmental impact that rest on carbon credits generated outside the company’s own value chain. What remains possible is stating facts precisely: that emissions are measured, what has actually been reduced, and that guests can support climate projects — provided none of it is presented as neutrality.

Hotels may continue to display sustainability labels based on a certification scheme with transparent, publicly available criteria and independent third-party verification, or labels established by public authorities. In practice this covers schemes such as the EU Ecolabel, the Austrian Ecolabel and other ISO 14024 Type I labels, GSTC-recognised hospitality schemes and management-system certifications such as ISO 14001 — while in-house badges and self-awarded ratings do not qualify.

An already certified hotel still benefits from a green claims review, because certification covers the scheme’s own scope while EmpCo covers everything the property communicates. Certified hotels commonly carry additional uncertified claims — a “climate-neutral” package, a self-made leaf icon, an unqualified “sustainable” line in an OTA listing — and it is those claims, not the certificate, that create the exposure.

A HOLITRA green claims review is sustainability advisory work, not legal advice: it establishes what can be substantiated, documents the evidence behind each claim and provides corrected wording. Where a formal legal assessment or a litigation position is required, HOLITRA works alongside the client’s legal counsel rather than replacing them.