On 27 September 2026, Directive (EU) 2024/825, the Empowering Consumers for the Green Transition Directive (EmpCo), becomes enforceable across the EU. It amends the Unfair Commercial Practices Directive. Generic claims like "eco-friendly," "sustainable" or "green" without evidence become an unlawful commercial practice. Penalties for widespread infringements run up to 4% of annual EU turnover or €2 million, whichever is higher.
That's four months from now.
The OTAs are already there. Booking.com retired its in-house Travel Sustainable badge in March 2024 under pressure from the Dutch ACM and now requires third-party certification to appear in sustainability filters. About 28,000 properties qualify today; over 500,000 that carried the old badge no longer do. EmpCo codifies the direction the platforms set.
Travellers are too. According to forthcoming Phocuswright research on British, French, and US travellers, 79% would pick a 4-star bed-bug-safe-certified hotel over an uncertified 5-star. Half would take a certified room over a free upgrade. Pests now top room price and location as the number one booking concern.
Hotels that can prove what they say will win these guests. The rest will quietly lose them.
Most hotels are not doing badly on sustainability. There's a sustainability page, a green programme, a recycling commitment, a linen card. What changed is the rules underneath those claims. A leaf logo someone designed in-house? Not allowed. "Carbon-neutral meeting" based on offsets outside your value chain? Banned. "Eco-friendly room" with no third-party audit? Now an unlawful commercial practice, with penalties up to 4% of EU turnover.
The work is editorial. You check every surface where sustainability language appears and produce a defensible answer for each claim.
We built a 28-point checklist for European hotel operators. It walks through every surface where sustainability claims show up and tells you what passes the 27 September test and what doesn't. Six sections:
Vocabulary on your website and OTA. The directive's full banned-terms list (environmentally friendly, eco-friendly, eco, green, natural, sustainable, ecological, climate-friendly, climate-neutral, energy-efficient, biodegradable, plastic-free, biobased) stress-tested against your live copy.
Carbon-neutral and climate-neutral claims. The words now banned outright when based on offsets, and the rewrites that still work.
Logos, badges, and certifications on display. Under EmpCo, a sustainability label must rest on a certification scheme or be authorised by a public authority, with credibility verified by an independent third party. Chain-internal programmes like Planet 21, Green Engage, LightStay or Serve 360 don't clear that bar on their own.
Future commitments. What makes a "net-zero by 2030" pledge legal under the new rules, and what makes it a breach.
Substantiation. The evidence trail a regulator, a journalist or a guest can request, and your team has 24 hours to produce.
Beyond the website. Emails, RFPs, room cards, signage, sales decks. A clean website with one bad line in a confirmation email is still a breach.
You can run the checklist in about 20 minutes, with your website, your OTA listing and your pest control contract on hand.
There's one part of the checklist that catches most properties out, because it sits in a gap the major sustainability schemes don't audit deeply. Pesticide use.
Hotels are heavy indoor users of neonicotinoid pesticides, and almost none of that usage is tracked at the corporate level. It doesn't show up in GRI, Green Key, Travelife or LEED. So when a hotel writes "chemical-free," "eco-friendly room" or "pesticide-free guest rooms" on the website, the property often can't substantiate it, because no one knows what's actually in the pest control contract.
Under the new rules, that's a claim you can't defend. The checklist shows where this gap fits in the audit, and how to close it.
The simplest fix: open your pest control contract and check whether it names imidacloprid, clothianidin, thiamethoxam or any other neonicotinoid. If it does, you can't honestly publish "chemical-free" or "eco-friendly room" on your website today. Either the contract changes, or a room-level certification does the work the contract can't.
Valpas is a Layer 2 issue-level certification for pesticide-free and bed-bug-safe guest rooms. Audited by Bureau Veritas. Recognised by the GSTC and the Sustainable Hospitality Alliance. Verified at room level. Live today across more than 300 properties in 60+ destinations, including Marriott and Aman. It sits alongside your property-level scheme (EU Ecolabel, Green Key or Travelife) and substantiates a class of claim those schemes don't audit. The checklist explains how the layers fit together.
Four months is enough time to fix this. The deadline isn't going to move. Get the 28-point checklist sent to you, run it against your website and OTA listings this week, and you'll know exactly which claims you can keep, which need rewriting, and which need to come down before 27 September.
Get your free sustainability claims checklist sent to you via email
This guide is operational information for hotel teams, not legal advice. For legal advice on your situation, consult qualified counsel.
