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.