On 27 September 2026, Directive (EU) 2024/825 — the Empowering Consumers for the Green Transition Directive — becomes enforceable across the EU. Here is what you need to know and do before the deadline, with a downloadable action checklist for your hotel.
The directive applies to any hotel marketing to EU travellers — not just hotels based in Europe. If your property or brand reaches EU consumers through your website, OTA listings, loyalty programmes, digital advertising, or corporate travel marketing, you fall within scope.
For Middle East hotels with European markets, this is a commercial issue that touches marketing, sales, distribution, and brand reputation.
The major booking platforms have been heading in this direction for two years. Booking.com withdrew its Travel Sustainable badge in early 2024 following pressure from the Netherlands Authority for Consumers and Markets, switching instead to a model that requires independent third-party certification
What the directive actually bans
Most hotels are on the right path to operating sustainably. Sustainability goals and KPIs, green initiatives, a recycling commitment. What’s changed is the legal ground underneath those claims. The directive’s prohibited terms list is specific. The following words and phrases — when used without verified substantiation — become unlawful commercial practices: environmentally friendly, eco-friendly, eco, green, natural, sustainable, ecological, climate-friendly, climate-neutral, carbon-friendly, energy-efficient, biodegradable, bio-based, plastic-free.
If any of these appear on your website, OTA listing, room cards, sales materials, or confirmation emails without evidence to back them up, they need to be revised before September.
Carbon and climate claims carry additional weight. “Carbon-neutral,” “climate-neutral,” “carbon positive,” and “reduced climate impact” are not permissible when based solely on offset purchases. The future of sustainability communication is about measurable reductions achieved within your own operations.
Future pledges like “net-zero by 2030” must be backed by a detailed, realistic implementation plan, regularly reviewed by an independent, accredited third party.
Replace claims with evidence
The hospitality industry needs to rethink how it talks about sustainability. The shift is from adjectives to evidence. Certification alone is not a marketing strategy, but it is increasingly the foundation for strong sustainability communications.
Instead of “We are an eco-friendly hotel,” say “Green Key certified property, audited annually against international sustainability standards.”
Instead of “Carbon-neutral stay,” say “Operational emissions reduced by 28% since 2019, independently verified through annual reporting.”
Instead of “Sustainable meetings package,” say “Meetings programme certified against independently verified sustainability standards, including measured waste diversion and energy reduction.”
Specificity builds trust. Vague claims create risk.
A sustainability label must be based on a recognised certification scheme or authorised by a public authority, with credibility verified by an independent third party. Recognised certifications that will hold up under the directive include EU Ecolabel, Green Key, EarthCheck, Travelife, Biosphere, and Green Globe.
Management systems such as ISO 14001 and ISO 50001 also strengthen credibility, though they are process-focused rather than claim-focused.
Corporate buyers are moving faster than regulators
Even hotels with limited direct exposure to EU consumers should not assume they are unaffected. Corporate travel buyers and procurement teams are already revising sustainability questionnaires and RFP requirements.
Increasingly, buyers are asking which third-party certifications a property holds, how sustainability claims are verified, and what emissions reductions have actually been achieved.
In many cases, hotels may lose business opportunities long before any regulatory enforcement occurs.
What’s in the checklist:
The checklist includes a points to review:
- Review Customer-Facing Content
Audit all guest-facing digital content, including website pages, property descriptions, F&B and wellness messaging, events materials, and loyalty programme communications. - Identify Prohibited Language
Check for prohibited environmental terminology, unsupported climate-related statements, and self-created labels or badges that lack recognised third-party certification. - Verify Supporting Evidence
Ensure every remaining environmental statement can be substantiated with clear, current, and preferably independent evidence if challenged.
To access the checklist, reach out to us at info@sustainabilitykiosk.com
How Sustainability Kiosk can get your hotel ahead
With just three months remaining before the Directive takes effect, now is the time for hospitality businesses to assess whether their sustainability claims can withstand regulatory scrutiny. A focused 90-day audit provides a practical starting point, helping teams identify potential risks, close compliance gaps, and strengthen the credibility of their communications before enforcement begins.
At Sustainability Kiosk, we understand the realities of the hospitality sector because we operate where operational delivery, sustainability standards, commercial objectives, and regulatory expectations converge.
We know how well-intentioned claims can become vulnerable when they are not backed by the right evidence, governance, or processes. More importantly, we help organisations rebuild and refine those claims so they remain credible, compliant, and operationally practical.
The goal is simple: ensure every sustainability claim is accurate, supported, and ready for increased regulatory oversight while maintaining the trust of guests, investors, and commercial partners.
To know more, email the team on info@sustainabilitykiosk.com
👇Download the Sustainability Kiosk 90-Day Audit Checklist for your hotel:
