New EU Directive on Environmental Advertising impacts the way Hotels communicate their Sustainability Credentials

This new Directive introduces strict rules for certain types of environmental advertising (“green advertising”) and will have a significant impact on the way hotels communicate their sustainability credentials with consumers. Any current communication that is still available on the market on 27 September 2026 must also comply with the new rules.

Prohibition on Generic Environmental Claims

Most notably, the Directive will set a high bar for the use of so-called “generic environmental claims”. Using these terms to advertise the ecological impact of hotels will require specific substantiation or, lacking such substantiation, may require special certifications. The Directive presents examples of generic claims in a non-exhaustive list. The list includes:

‘environmentally friendly’, ‘eco-friendly’, ‘green’, ‘nature’s friend’, ‘ecological’, ‘environmentally correct’, ‘climate friendly’, ‘gentle on the environment’, ‘carbon friendly’, ‘energy efficient’, ‘biodegradable’, ‘biobased’

Whether or not the use of these terms is considered generic depends on the context: if sufficient explanation is provided jointly with the claim, it may be considered non-generic (and as such fall under the yet to be adopted Green Claims Directive). For example, if a hotel wants to communicate that they are energy efficient, they must name specific examples of how and why they are energy efficient. Without such explanation, the claim “energy efficient” will be considered generic.

If a claim is found to be generic, it will require “excellent recognised environmental performance”, relevant to the claim, meaning:

Environmental performance compliant with Regulation (EC) No 66/2010 of the European Parliament and of the Council or with national or regional EN ISO 14024 type I ecolabelling schemes officially recognised in the Member States, or top environmental performance in accordance with other applicable Union law.

Only if such excellent recognised environmental performance can be shown and only if it is relevant to the claim, can a generic environmental claim be used.

Last but not least, the Directive explains that hotels should not use generic claims such as ‘conscious’, ‘sustainable’ or ‘responsible’ solely based on “excellent recognised environmental performance”, as such claims also relate to other characteristics, such as social characteristics. Only if social characteristics are improved as well, may these terms be justified.

Sustainability Labels

Many sustainability labels, which are commonly used by hotels, travel agencies and booking portals, will require significant change to remain on the market. Whether it is a leaf, a tree icon or a green seal, their use will either require that they are established by public authorities or that they are based on a “certification scheme”. The latter is of most interest, as it is the only option for private sustainability labels.

A certification scheme is, inter alia, a third-party verification scheme, in which the sustainability label user (e.g. the hotel), the sustainability label owner and the sustainability label verifier must be three independent parties. The scheme must operate under transparent and fair terms to all it must be developed in consultation with relevant experts and stakeholders.

In short: if a hotel or booking platform is currently operating their own sustainability label, they might have to cease use of the label by 2026 or open it up to all competing hotels and transfer ownership to an independent party. However, we will have to see how these provisions will be implemented into national laws to assess their impact on existing private sustainability labels on a per country basis.

Future Environmental Performance

Advertising promises and plans for the reduced environmental impact of hotels (such as: “by 2030 our hotel’s ecological impact will be reduced by…”), will:

• require clear, objective, publicly available and verifiable commitments;
• be set out in a detailed and realistic implementation plan that includes measurable and time-bound targets and other relevant elements necessary to support its implementation, such as budgetary resources, technological developments, allocation of resource.

This plan must also be regularly monitored by an independent third-party expert (with experience and competence in environmental issues), whose findings must be made available to consumers.

This change will impact communications regarding goals and ambitions and will require concrete plans, steps and a published monitoring.

Claims based on Greenhouse Gas Emission Offsets

Using offsetting to claim a Greenhouse Gas Emission neutrality of the services of hotels will be banned. In particular, it will be prohibited to claim, based on greenhouse gas emissions offsetting, that the services of a hotel have a neutral, reduced or positive impact on the environment in terms of greenhouse gas emissions.

Examples of such claims are ‘climate neutral’, ‘CO2 neutral certified’, ‘carbon positive’, ‘climate net zero’, ‘climate compensated’, ‘reduced climate impact’, ‘limited CO2 footprint’. This change will be an obstacle for many hotels aiming for a globally aligned advertising, as many other countries still allow neutrality advertising based on offsetting.

Written by: Constantin Eikel