Hotel Green Claims After 27 September: From Wording to Evidence
Since 27 September 2026, the EU Empowering Consumers Directive (EmpCo) applies across the European Union — and with it, stricter rules for hotel green claims.
Many hotels have reacted the same way. The website was checked. “Eco” became “environmentally conscious”. “Climate-neutral” disappeared from the homepage.
This is a reasonable first step. But it rarely covers the full picture.
Hotel green claims do not only live on the website. They live on booking platforms, in offers and packages, in printed materials, newsletters and brochures — and in what the reception team says when a guest asks why towels are not changed daily.
In April, we described what EmpCo means for hotels and why the real issue is evidence, not vocabulary. This article is the practical follow-up: what a credible review of hotel claims covers — and where the difficult decisions lie. It is also why green claims compliance is an ongoing task rather than a one-off text edit.
Common misconception
“We have updated the wording on our website, so our green claims are compliant.”
Not necessarily. A claim is not only a sentence on a web page. Every channel that communicates environmental benefits counts — and a rewritten claim without evidence behind it is still an unsupported claim.
Why Hotel Green Claims Need More Than a Text Edit
EmpCo — Directive (EU) 2024/825 — amends the EU rules on unfair commercial practices towards consumers. These rules cover services, and therefore a hotel stay. In Germany and Austria, the directive has been transposed through amendments to the respective Unfair Competition Acts (UWG).
Two points make this relevant far beyond the website:
- Some practices are now prohibited outright. They are on the EU “blacklist” and considered unfair in all circumstances — without a case-by-case assessment of whether guests were actually misled.
- Enforcement in DACH is largely private. Unfair competition rules are typically enforced through cease-and-desist letters and injunctions by competitors and entitled associations. A claim does not need to attract a regulator to become a problem.
Rewording is not the same as reviewing
Wording-led approach
- The website is checked, other channels are not
- Risky words are replaced with softer synonyms
- Evidence is assumed to exist somewhere
- Marketing decides alone
- The review is done once
Evidence-led approach
- All channels are considered
- Each claim is assessed by type and risk
- Every kept claim is substantiated
- Operations, marketing and management share responsibility
- Claims are reviewed when operations change
What a Credible Review of Hotel Green Claims Covers
A credible review is not a legal memo. Its purpose is a hotel that knows what it says, why it can say it, and who is responsible for keeping it true. It covers four areas:
- All channels — not only the website, but also platform listings written years ago, offers, printed materials, imagery and what staff say.
- The type of each claim — some claim types are now prohibited, others are permitted only under specific conditions.
- The substantiation of every claim that stays — assessed against what the claim actually says.
- Responsibilities — so that claims do not drift away from reality with the next offer, campaign or platform update.
The examples below show three claim types that are particularly common in hotels.
Three typical hotel claims — and why they are problematic
| Claim | Type | Why it is problematic |
|---|---|---|
| “Eco hotel”, “green holiday” | Generic claim | Only permitted with recognised excellent environmental performance relevant to the claim — for example the EU Ecolabel or an officially recognised EN ISO 14024 Type I ecolabel such as the Austrian Ecolabel. |
| “Climate-neutral stay” | Offset-based neutrality claim | Prohibited where the neutral, reduced or positive impact is based on offsetting. |
| An in-house “green promise” badge or leaf icon used as a sustainability label | Self-created label | Prohibited unless based on a certification scheme with independent third-party monitoring or established by public authorities. |
Examples for orientation, not legal advice. Annex I of Directive 2005/29/EC as amended by Directive (EU) 2024/825.
Where the Real Difficulty Lies: A Document Is Not Yet Evidence
Most hotels have more documentation than they expect: energy contracts, purchasing records, certificates, audit reports.
The difficulty is rarely finding documents. It is judging whether a document actually supports the specific claim being made. For example:
- A renewable electricity contract covers the main building — but not the spa or the staff house that the claim implicitly includes.
- A certificate is valid — but its scope differs from what the website suggests.
- “Regional” appears on the menu — but there is no definition, and purchasing data support it only in part.
- A climate target is published — but without the implementation plan and independent verification the directive requires for future performance claims.
In each case, the documentation exists. The claim is still not covered.
These are judgement calls. They require understanding the legal requirements, the certification schemes and hotel operations at the same time — and they determine which claims can stay, which need to be reworded and which have to go. This is also where green claims meet sustainability data and reporting: a claim can only be as reliable as the data and definitions behind it.
Certification helps — but it is not a licence for every claim
What certification provides
- A label based on independent third-party verification
- Structured evidence across many topics
- A regular audit cycle that keeps data current
- Credibility with platforms, B2B clients and guests
What it does not automatically provide
- A basis for every generic claim — EmpCo links generic claims to specific ecolabels or EU-level performance
- Coverage of claims outside the certificate’s scope
- Protection once the certificate has expired or the scope has changed
- Control over what other channels say about the hotel
This distinction matters for hotels with different certifications. A hotel certified under a GSTC-recognised scheme can display its label and make specific, evidenced claims — but on the wording of the directive, a generic claim such as “eco hotel” is tied to recognised excellent environmental performance, which refers to the EU Ecolabel, officially recognised Type I ecolabels or top performance under EU law. Choosing a certification and planning communication should therefore be one decision, not two — which is why certification consulting and communication planning belong together. The free HOLITRA Certification Toolkit can help hotels compare routes before committing.
An illustrative example: the claim nobody owned
The following example is a composite based on typical situations, not a single client case.
A family-run hotel had removed “climate-neutral” from its website in summer. Internally, the topic was considered closed.
An OTA listing, however, still described the property as a “climate-neutral hotel” — a text from an offsetting programme that had ended two years earlier. Nobody in the hotel was responsible for platform texts, and nobody had looked at this one since it was written.
The result: the claim the hotel had deliberately withdrawn was still its most visible sustainability message to international guests — and it belonged to exactly the type that is now prohibited.
The risk was not the hotel’s sustainability performance. It was a claim without an owner.
Green Claims as Part of the Hotel Sustainability System
Green claims are the visible end of a longer chain. What a hotel can credibly say depends on what it does in operations, how it measures it, whether it is independently verified and how it is managed over time.
For family-run hotels in particular, the substance is often stronger than the communication. The risk lies in texts that have grown over many years, across many channels, without a clear owner.
This is why we treat green claims within the Standards & Certifications pillar of the hospitality sustainability system — and why keeping claims aligned with reality belongs to continuous improvement, not to a single campaign. Key terms are explained in our hospitality sustainability glossary.
Frequently asked questions about hotel green claims
Frequently asked questions about hotel green claims
Yes. EmpCo amends the EU rules on unfair commercial practices towards consumers. These rules apply to goods and services, including accommodation, food and beverage, events and wellness offers.
“Sustainable hotel” is a broad claim covering environmental and social characteristics. An environmental ecolabel alone does not substantiate it. Hotels should communicate specific, evidenced achievements and describe their certification accurately, within its scope.
Not where the claim is based on offsetting emissions. Hotels can report their contributions to climate projects separately, but not present the stay or the property as neutral because of them.
No. A valid certification under a scheme with independent third-party verification allows the hotel to display the label and supports specific claims within its scope. It does not automatically justify generic claims, claims outside the certified scope, or claims after the certificate has expired.
The proposal has not been adopted. In June 2025, the European Commission announced its intention to withdraw it. EmpCo, as transposed into national law, is the framework that applies today.
The better question: not “which words are still allowed”, but “what can we prove”
Many hotels approached EmpCo as a vocabulary question. Which words are banned? Which synonyms are safe?
The more useful question is different: what does the hotel actually do, how is it measured, who verifies it — and does every channel say the same thing?
This question does not have a one-off answer. Operations, suppliers, certificates and channels change — and with them, what a hotel can credibly say.
Credible sustainability communication does not start in marketing. It starts with operations, data and verification — and marketing is where it becomes visible.
Is what your hotel communicates supported by what it does — and can prove?
HOLITRA assesses the relationship between your hotel’s sustainability claims, its actual operations and the available evidence — identifying gaps, priorities and responsibilities, and connecting the result to certification and reporting. This is sustainability advisory work, not legal advice.
Discuss your green claims →