EmpCo and Green Claims: What Hotels Actually Need to Get Right
The new EU Empowering Consumers Directive (EmpCo) is significantly changing how sustainability is communicated in the hospitality sector and beyond. While much of the current discussion focuses on restrictions—what companies are no longer allowed to say—the actual impact goes further.
EmpCo is part of a broader regulatory shift addressing so-called green claims, meaning environmental statements used in marketing and communication. These include terms such as “sustainable”, “eco-friendly”, “climate neutral” or similar expressions that suggest environmental benefits.
Under the new rules, such claims must no longer be vague or purely promotional. Instead, they need to be clear, specific and supported by verifiable evidence. At the same time, the use of sustainability labels is being tightened, particularly where these are not based on recognised certification systems or lack independent verification.
For hotels, this does not mean that sustainability communication is no longer possible. It means that it must be grounded in reality.
In practice, however, many organisations are reacting primarily on the level of language—adjusting wording, removing certain terms or replacing them with safer alternatives. What is often missing is a deeper question:
What needs to be in place before a sustainability claim can be made at all?
What are green claims and what does EmpCo regulate?
Green claims refer to any form of communication that suggests or creates the impression that a product, service or organisation has a positive environmental impact, is less harmful to the environment, or performs better than others in terms of sustainability.
This includes not only explicit statements such as “we are sustainable”, but also indirect messages through:
Certifications and labels
Visual elements (e.g. green imagery, symbols)
General positioning in marketing materials
Requirements for hotels & tourism
EmpCo specifically addresses misleading practices in this area. It strengthens existing EU consumer protection legislation by introducing stricter requirements for environmental claims and banning certain types of communication altogether.
In particular, the directive:
- restricts generic environmental claims that cannot be substantiated
- limits the use of sustainability labels that are not based on recognised certification schemes
- requires that environmental claims are supported by clear and verifiable evidence
- aims to make sustainability information more transparent and comparable for consumers
This regulatory development is closely linked to the upcoming Green Claims Directive, which will further define how environmental claims must be substantiated and verified.
For hotels, this creates a new level of accountability—not only in what is communicated, but in how sustainability is implemented and documented internally.
Beyond wording: where the real challenge lies
A common misconception is that EmpCo is primarily about communication and marketing language. As a result, many organisations focus on adjusting terminology: avoiding certain words, reformulating statements, or simplifying their messaging.
However, this approach only addresses the surface.
EmpCo does not prohibit sustainability claims as such. It requires that these claims are credible. This shifts the focus from how something is said to what stands behind it.
It requires that environmental claims are:
- clear
- specific
- and supported by evidence
At the same time, it restricts:
- generic claims such as “eco-friendly” or “green”
- labels that are not based on recognised certification systems or established by public authorities — often lacking transparent criteria and independent verification
- claims that suggest environmental benefits without proof
This shifts sustainability communication from marketing language → to verifiable statements.
What this means in practice: examples of claims
The difference between compliant and non-compliant communication is often not obvious.
It is not about avoiding certain words entirely.
It is about how precisely they are used — and what stands behind them.
“We are a sustainable hotel.”
Problem: Too generic with no clear definition and no measurable basis
“Stay climate neutral with us.”
Problem: Often based only on offsetting, can be misleading under EmpCo Directive
“We are certified.”
Problem: Unclear by whom, based on which criteria and what type of certification
“Award-winning sustainable hotel”
Problem: Awards are not verification systems, often based on jury decisions
Where many hotels struggle
In practice, the main challenge for hotels is rarely the wording of sustainability claims itself. Most organisations are already aware that generic statements such as “sustainable” or “eco-friendly” are no longer sufficient under the EmpCo Directive and broader EU green claims regulation.
The real issue lies deeper. It is the gap between what is communicated externally and what is actually implemented within the organisation.
Many hotels have taken initial steps in sustainability, often with strong intentions. However, these efforts are not always structured, measured or consistently documented. As a result, communication tends to move ahead of operational reality.
This becomes visible in several typical patterns. Claims are made without measurable data to support them. Labels are used without a recognised certification system or transparent criteria behind them. Sustainability is positioned as part of marketing, rather than embedded in day-to-day operations.
Under previous conditions, such gaps often remained unnoticed. With EmpCo and the increasing focus on green claims in the EU, these inconsistencies become more visible—and more risky.
The directive does not create the gap. It exposes it.
An overlooked factor: advisory quality
Another aspect that is still rarely addressed in the discussion around EmpCo and green claims is the role of advisory.
Sustainability consulting has become a rapidly growing field, particularly in hospitality. Hotels are increasingly looking for external support to define their sustainability strategy, select certifications or shape their communication.
At the same time, the market has become highly heterogeneous.
There is a wide range of approaches—from structured, framework-based advisory grounded in recognised standards, to concepts that are primarily driven by communication and positioning. While both may appear similar on the surface, the outcomes they produce can differ significantly.
This becomes critical in the context of EmpCo.
The quality of advisory directly influences how sustainability claims are formulated, what data is collected, and how robust the underlying system is. In other words, it has a direct impact on the credibility of communication and the risk of non-compliance with EU green claims requirements.
For hotels, this raises an important but often overlooked question:
not only what is communicated, but also on what basis these claims are developed.
What hotels and tourism organizations should do now
In response to EmpCo, many organisations initially focus on adjusting their wording. While this is a necessary step, it is not sufficient.
A more effective approach is to step back and assess the substance behind the communication.
Before making or revising sustainability claims, hotels should consider several key questions.
What exactly are we doing in operational terms—and can we demonstrate it with reliable data? Are our sustainability claims specific enough to be clearly understood and verified? Do they refer to recognised standards or frameworks, such as those commonly used in hospitality? And would our communication withstand external scrutiny, whether from regulators, partners or increasingly informed guests?
These questions reflect the shift introduced by EmpCo. The directive does not require organisations to be perfect or fully transformed. However, it requires consistency.
Consistency between what is communicated and what is actually implemented.
Consistency between claims and evidence.
Consistency between positioning and reality.
Conclusion
EmpCo is often perceived as a restriction on sustainability communication.
In reality, it is better understood as a correction.
It shifts the focus from general statements and broad positioning towards credible and verifiable claims. It encourages organisations to move beyond marketing language and align their communication with measurable, transparent and substantiated practices.
For hotels, this represents both a challenge and an opportunity.
While certifications, frameworks and audits provide essential structure and support, they cannot replace the underlying foundation.
A genuine commitment to doing things properly.
Because ultimately, sustainability is not defined by wording alone.
It is defined by what stands behind it.
