What green claims compliance means for hotels
Every environmental statement a hotel publishes — website, OTA listings, booking engine, in-room signage, menus, guest folder — has to be specific, substantiated and documented. Since 27 September 2026 that is no longer good practice but law: Directive (EU) 2024/825, the EmpCo Directive, written into German and Austrian unfair-competition law. In Switzerland, the Unfair Competition Act (UWG) applies.
Hotels are unusually exposed, because sustainability language accumulates over years across channels nobody owns centrally. HOLITRA reviews those claims from the evidence side: what can be proven stays, what cannot is rewritten, and every claim you keep has a documented record behind it, as part of ESG, Reporting & Assurance and the Reporting pillar of the HOLITRA Hospitality Sustainability System.
WHO THIS IS FOR
Who we support with green claims compliance
Hotels & Hotel Groups
A claims review for one hotel or for every property, brand and channel of a group, with one consistent wording.
Owners, Investors & Operators
Claims in investor, sales and guest communication that match what the properties can actually prove.
Associations & Industry Bodies
Green claims guidance and programmes for member hotels, built on the same hospitality expertise.
WHAT WE SOLVE
What HOLITRA does in green claims compliance
We keep your sustainability work visible to guests, and remove the claims that cannot be proven.
01
Claims across every channel
Website, OTA listings, booking engine, newsletters, social media, print, in-room signage and menus: the claims nobody owns centrally.
02
Prohibited wording
Generic terms, offset-based neutrality claims, self-made badges and legal minimums presented as achievements, found and taken out.
03
Substantiation
Each claim you keep linked to data, a certificate, a meter reading or an audit record. Carbon footprint →
04
Labels, seals & badges
Which labels and platform badges rest on independent third-party verification, and which have to come down. Certification →
05
Wording that still works
Specific, accurate claims that keep your sustainability work visible to guests, in German and English.
06
Claims governance
A sign-off route so the next campaign does not bring the problem back. Where marketing uses AI-generated or manipulated content, we check whether the AI Act transparency requirements apply, including disclosure for deepfakes.
WHAT YOU RECEIVE
What a green claims review delivers
The scope depends on how many properties and channels you communicate through. We agree the deliverables in writing before work starts.
01
Claims inventory
Every environmental statement you publish, collected in one register: website, OTA listings, booking engine, newsletters, social media, print, in-room signage and menus.
02
Risk classification per claim
Each claim rated prohibited, substantiation required, or compliant, with the specific rule it falls under named.
03
Evidence file
For every claim you keep: the data, certificate, meter reading or audit record that proves it, and a named gap wherever that proof is missing.
04
Rewritten wording
Compliant replacement text for every claim that fails, written in German and English and ready to publish.
05
Label and seal decision
A clear list of which labels, seals and platform badges you may continue to display, and which have to come down.
06
Green claims policy and sign-off route
A one-page internal rule defining who approves a sustainability claim before it goes live, so the next campaign does not reintroduce the problem.
WHAT EMPCO PROHIBITS
What the EmpCo Directive prohibits for hotels
Since 27 September 2026, these claims are no longer allowed in consumer communication across the EU.
Generic & whole-property claims
“Sustainable hotel”, “eco”, “green” without recognised excellent environmental performance, or built on one isolated measure.
Neutrality through offsetting
“Climate-neutral stay” or “CO₂-compensated night” based on credits purchased outside your own value chain.
Self-designed labels
Any badge, seal or in-house rating not based on a certification scheme with independent third-party verification.
Legal minimum as achievement
Advertising what the law already requires, such as the single-use plastics ban, as a distinguishing feature.
WHY HOLITRA
Why HOLITRA for green claims in hospitality
HOLITRA combines hospitality-specific sustainability expertise with the qualified specialists required by the scope of the project.
Built specifically for hospitality
We know where hotel claims hide — OTA descriptions, booking engines, menus, in-room cards — and which ones guests actually read.
The right expertise for the assignment
We bring the qualified expertise behind each claim, from certification schemes and buildings to carbon accounting.
Audit-minded evidence
We review claims from the evidence side, the way a consumer authority or a competitor would challenge them.
One connected system across disciplines
Your claims rest on the same data as your ESG report, carbon footprint and certification: one evidence base, consistent everywhere.
HOW WE WORK
How a green claims review works
A first review depends on how many properties and channels you communicate through.
01
Collect
Every environmental claim gathered from your channels, properties and printed material.
02
Classify
Each claim checked against the EmpCo rules and rated prohibited, substantiation required or compliant.
03
Substantiate
Evidence collected for the claims you keep; gaps named where proof is missing.
04
Rewrite
Compliant wording for every claim that fails, in German and English.
05
Labels & policy
The label and badge decision, and a sign-off route for future claims.
06
Monitor & update
New campaigns and channels checked against the same rules, continued as ongoing sustainability management if you want support year on year.
Go deeper
Practical insights into EmpCo, sustainability certification and certification readiness in hospitality.
FAQs
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 has applied across the European Union since 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.
Penalties reach up to 4% of annual turnover for widespread infringements, and claims can be challenged by competitors and consumer associations, not only by authorities. Platforms are already acting: Booking.com withdrew its own “Travel Sustainable” badge after the Dutch consumer authority intervened, and now recognises third-party certifications only.
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.
EmpCo is EU law. In Switzerland, environmental and climate claims fall under the Unfair Competition Act (UWG) and must likewise be accurate and verifiable. The same review approach applies; we check the claims against the rules of the market where they are published.
Not automatically. The EU AI Act requires disclosure for certain AI-generated or manipulated content, including deepfakes and certain text on matters of public interest. Human-reviewed marketing copy under editorial responsibility is not automatically subject to an AI label. The environmental claim itself must still comply with the applicable consumer and green claims rules, regardless of whether AI was used to create it.
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.
Find out what has to change
Send us your website, your OTA listings and your printed guest information. We tell you what has to change and what you can keep.