Sustainable Travel | Responsible Travel | Sustainable Tourism

Be In Good Standing

Here’s the situation in Europe on laws around sustainability which we update quarterly.

For Hotel Owners or CEOs or GMs, we included the laws from government websites and insights from 3rd parties that you should be reading. We also included NOW Insights - Impacts to the Hspitality Industry.

Q1 2026 Update - EU Sustainability Framework & Insights +

The EU Sustainability Framework is a comprehensive set of regulations, directives, standards, and initiatives, anchored by the European Green Deal, aiming to shift the EU economy to a climate-neutral, sustainable model by 2050, primarily through mobilizing private investment in green activities, enhancing corporate transparency, and preventing greenwashing.

This interconnected system classifies sustainable activities, mandates disclosures for financial products and companies, and sets due diligence rules for responsible business, all while balancing environmental goals with economic competitiveness.

EU regulations are binding legal acts that apply directly and uniformly across all European Union member states, becoming law automatically without needing national legislation. They are comprehensive, binding in their entirety, and aim to ensure consistent application of EU law for citizens, businesses, and governments.

EU directives must be transposed into national law by Member States by the deadline date or they risk infringement procedures by the European Commission, potentially leading to European Court of Justice (ECJ) fines.

Communications, Reporting & Disclosure

EU Corporate Sustainability Reporting Directive (CSRD) +

EU CORPORATE SUSTAINABILITY REPORTING DIRECTIVE (CSRD) Directive (EU) 2022/246

Adopted
Nov. 28, 2022

Published
Dec. 16, 2022
Enforced
Jan. 5, 2023

Transposed in EU Member States deadline
Jul. 6, 2024

Applied in Phases Report
FY2024 FY2025/2026 FY2027/2028

Omnibus/ Stop-the-Clock transposition delayed to
Dec. 31, 2025

The CSRD is a European Union (EU) legislation that require companies above certain sizes and listed companies to publish regular reports on what they see as the risks and opportunities arising from social and environmental issues, and on the impact of their activities on people and the environment. Smaller companies will be affected indirectly, necessitating alignment with EU-level sustainability reporting.

Published in EU Official Journal: https://eur-lex.europa.eu/eli/dir/2022/2464/oj/eng

Penalties

Vary by Member State and designed to be effective, proportionate, and dissuasive for non-compliance.

Heavy financial fines (eg. up to €10M or 5% of global turnover in Germany or France's up to €18,750)
Public disclosure ("naming and shaming")
Criminal sanctions for severe breaches ie. Up to 5 yrs imprisonment in France for failing assurance or obstructing audits (lack 3rd party audit from accredited Certification Body)
Fines and exclusion from public contracts for general non-compliance
Significant reputational damage

The Omnibus Package

Omnibus Package was launched on 26 February 2025 to simplify and increase focus on EU competitiveness by reducing administrative burdens by 25% for all businesses and 35% for SMEs. Modifies CSRD.

Narrowed Scope: CSRD will primarily apply to large companies with over 1,000 employees, reducing the number of directly affected entities.
Delayed Reporting Timelines:
- FY 2024 (due 2025): Large public-interest entities (500+ employees) already subject to previous NFRD.
- FY 2025/2026 (Delayed): Other large companies and listed SMEs were originally set to report, but this is being postponed by the "Stop the Clock" Omnibus proposal, with many moving to FY 2027/2028 (due 2028/2029).
- Non-EU Companies: Must start reporting in 2029 (for FY 2028).
Omnibus Package has a broad reach. Despite scope changes, the interconnectedness with EU partners means many non-EU companies (like Swiss firms) must still comply or adapt to meet supply chain requirements. While SMEs are not directly in scope, they will face significant indirect pressure from large partners to provide data and prove their credible sustainability credentials.

The ‘Stop-the-clock’ directive postpones by one year the application of certain due diligence requirements and transposition deadline; and by two years, the entry into application of the CSRD requirements for large companies that report from financial year 2025 (FY2025) and 2026 (FY2026), the so‑called “wave two” and “wave three” companies, as well as listed SMEs. A targeted “quick fix” amendment was also adopted to reduce burden for companies that had to start reporting for financial year 2024 (FY2024), commonly referred to as “wave one”.

Switzerland's Regulatory Alignment

Swiss companies that have subsidiaries or branches in the EU are expected to comply with the CSRD. To align with CSRD in Switzerland, the Swiss Federal Council amended its Code of Obligation (Articles 964a-c) on Jan. 1, 2026.

Swiss Publication Platform: Code of Obligations - Transparency on Non-Financial Matters (Articles 964a-c).

Penalties

Fines may be imposed for failing to make the required reports, making false statements in the reports, and failing to comply with the legal obligation to retain and document the reports.

Criminal Fines for Individuals: According to Art. 325ter of the Swiss Criminal Code (SCC), individuals (such as board members) responsible for preparing reports who wilfully violate the obligations are subject to fines of up to CHF 100,000.
Negligent Breaches: If the breach of reporting obligations is due to negligence rather than intent, the maximum fine is reduced to CHF 50,000.
Corporate Liability: While the company itself cannot be directly fined for violations of Art. 325ter SCC, if the breach cannot be attributed to a specific person due to inadequate organization, a fine of up to CHF 5 million can be imposed on the company under Article 102 of the Criminal Code.

INSIGHTS

KPMG: Mar. 17, 2025 - Omnibus Simplification Package of the European Commission

PwC Switzerland: Mar. 3, 2025 - EU Commission publish Omnibus Proposal

Boston Consulting Group: Mar. 2025 - EU Omnibus Package - How Companies Should Adjust their Sustainability Reporting

Deloitte: Feb. 16, 2025 - European Sustainability Reporting - Omnibus

Stibbe: Jan. 7, 2022 - Omnibus I: clarity on the future of the CSRD and CSDDD

NOW Insight: Impacts to the Hospitality Industry

CSRD significantly impacts the hospitality industry by mandating detailed ESG (Environmental, Social, and Governance) Reporting, driving operational changes towards sustainability (environment, social and financial) and increasing transparency to all stakeholders.

This creates challenges (administrative burden, data collection) and opportunities (competitive advantage, resource efficiency) for hospitality companies, especially larger ones and those catering to business travel (MICE). For mandatory reporting and communication to stakeholders, companies must now rigorously track metrics like energy, water, waste, and carbon footprint to align with new European Sustainability Reporting Standards (ESRS), implement a sustainability criteria or standard which must be audited by an accredited Certification Body to obtain certifications.

CSRD elevates sustainability from a voluntary marketing point to a mandatory, data-driven business imperative for the hospitality sector, especially for those serving the EU market.

EU Empowering Consumers for the Green Transition Directive (ECGTD) +

EU EMPOWERING CONSUMERS FOR THE GREEN TRANSITION DIRECTIVE (ECGTD) Directive (EU) 2024/825

Adopted
Feb. 28, 2024

Published
Feb. 28, 2024

Enforced
Mar. 27, 2026

Transpose in EU Member States
Mar. 27, 2026

Apply rules in EU Member States
Sept. 27, 2026

ECGTD is a European Union (EU) legislation that aims to stop “greenwashing” by giving consumers better information about a product’s sustainability and encourage more sustainable purchases. It has a broad reach, affecting all companies in the EU and abroad that target the EU consumer.

It amends and makes stricter two existing EU directives. The Consumer Rights Directive was updated to include product durability, repairability, and software updates for digital goods. The Unfair Commercial Practices Directive was updated to ban misleading environmental claims and expand the list of misleading practices.

Published in EU Official Journal: https://eur-lex.europa.eu/eli/dir/2024/825/oj/eng

Penalties

Vary by Member State and designed to be effective, proportionate, and dissuasive for non-compliance.

Substantial fines up to 4% of annual turnover
Confiscation of illicit revenue gained from the misleading product or claims.
Public exposure
Bans from the market enforced by national bodies leveraging Unfair Commercial Practices Directive (UCPD) powers
Temporary exclusion from public tenders and access to public funds (up to 12 months)
Public disclosure of the violations ("naming and shaming")

Switzerland's Regulatory Alignment

Swiss companies that have subsidiaries or branches in the EU with sustainability claims are expected to comply with ECGTD.

Companies based in Switzerland with sustainability claims targeted to the EU Consumer will also be expected to comply with ECGTD.

For regulatory alignment with ECGTD, the Swiss Unfair Competition Act (UCA) has been amended to specifically target greenwashing by Jan. 1, 2025 with intensifying penalties.

Swiss Publication Platform: Federal Law on Unfair Competition Act (Articles 964a-c)

Penalties

The Swiss UCA relies on a mix of civil and criminal penalties for companies:

Civil Liability: Competitors, customers, and consumer protection organizations can file lawsuits for injunctive relief or to have the advertising removed (Art. 9 UCA).
Criminal Liability: Under Art. 23 UCA, intentionally engaging in greenwashing can result in fines up to CHF 540,000.
Corporate Fine: If a person cannot be held directly responsible due to inadequate organization, the company itself can face a fine of up to CHF 5 million.

NOTE: The State Secretariat for Economic Affairs (SECO) can take action, and environmental claims can be reviewed by the Swiss Commission for Fair Trading (SLK).

INSIGHTS

PwC Switzerland: Jun. 5, 2025 - ECGT Directive: Prove Your Sustainability Claims Are True!

OECD: May 2025 - Protecting & Empowering Consumers in the Green Transition – Misleading Green Claims

Bird & Bird: Feb. 22, 2024 - Directive to Empower Consumers for the Green Transition has been published

Compliance & Risk: Mar. 11, 2024 - EU Adopts Stricter Rules on Greenwashing & Misleading Product Information

NOW Insight: Impacts to the Hospitality Industry

ECGTD will seriously impact hospitality companies in the EU and abroad that make any sustainability related claims to an EU consumer.

Companies will have to prepare for scrutiny. ECGTD means

Any sustainability related terms (such as local, green, sustainable, conscious, climate friendly, ++) and claims (such as carbon reduction, carbon neutral, Net Zero, plant-based, regenerative, zero waste, ++) and communications or storytelling must be backed by robust, science-based evidence that is credibly audited by an independent, accredited Certification Body.
Product lifespan and repairability for hotel items (linens, furniture, appliances, etc) should be checked.
Communication should be accessible to stakeholders in at least one official language of the country where the information is visible.

VIEW the NOW Sustainability Reporting Tool and how Force for Good hotels use the tool to communicate with accountability, compliance and transparency to engage stakeholders:

EU Taxonomy Regulation (EUTR) +

EU TAXONOMY REGULATION (EUTR) Regulation (EU) 2020/852

Adopted
Jun. 2020

Published
Jun. 22, 2020

Enforced
Jul. 12, 2020

Applied in phases while EU Member States transposed related rules CSRD/CSDDD into national law. Started
Jan. 1, 2022

EUTR is a EU classification system that defines what counts as an environmentally sustainable economic activity.

It creates a common language to guide investments towards the European Green Deal goals, preventing greenwashing, and directing capital to green projects by setting clear criteria for six environmental objectives, including climate change mitigation, biodiversity, and circular economy. It requires large companies and financial market participants to report on the sustainability of their activities, aligning with the Sustainable Finance Disclosure Regulation (SFDR).

Published in EU Journal: https://eur-lex.europa.eu/eli/reg/2020/852/oj/eng

Penalties

The EU Taxonomy is a classification tool, but its disclosure requirements under related laws mean that failing to comply with taxonomy reporting effectively means failing to meet broader ESG obligations, leading to significant financial, legal, and market consequences.

Non-compliance leads to significant indirect penalties - fines, reputational damage, loss of investment, legal action, and market barriers - enforced by Member States under related ESG rules (like CSRD/SFDR) with potential jail time (up to 3 years) and massive corporate fines (e.g., 5% of turnover/2x benefit) for severe breaches, making robust, accurate reporting crucial.

INSIGHTS

KPMG: Get ready for the EU Taxonomy Regulation

Société Générale Securities Services: Everthing you need to know about the Taxonomy regulation

NOW Insight: Impacts to the Hospitality Industry

EUTR encourage hospitality companies to become demonstrably green by demanding stricter environmental standards, especially in building efficiency for construction/renovation, water-saving fixtures, energy, waste management and reporting, requiring significant investments in sustainable practices, renovations, and tech to meet criteria for "substantial contribution" to EU green goals, benefiting from potential financial incentives and meeting investor/consumer demand for sustainability.

Larger hospitality businesses must disclose their alignment with the Taxonomy, showing what percentage of their turnover, CapEx, and OpEx meets sustainable criteria. This requires detailed data collection and reporting under related rules like the Corporate Sustainability Reporting Directive (CSRD).

There are many opportunities for compliance. EUTR help channel finance towards sustainable hotels. Long-term efficiency gains from reduced water and energy use lower operating costs. Meeting the demand from eco-conscious travellers can potentially increase revenue. It future-proof businesses by aligning with evolving EU Green Deal objectives which will lead to stricter rules.

EU Sustainable Finance Disclosure Regulation (SFDR) +

EU SUSTAINABLE FINANCE DISCLOSURE REGULATION (SFDR) Regulation (EU) 2019/2088

Adopted
Nov. 27, 2019

Published
Dec. 9, 2019

Enforced
Dec. 29, 2019

Applied in phases. Level 1: Mar. 10, 2021
Level 2: Jan. 1, 2023
Taxonomy related amendments: Feb. 20, 2023
Revised simplification proposal delayed to 2027-2028

The Sustainable Finance Disclosure Regulation (SFDR) is a European Union rule requiring financial firms (asset managers, advisors, etc.) to be transparent about how they integrate sustainability risks and impacts (ESG factors) into their investment processes, telling investors how their products affect the environment/society and how sustainability risks affect returns. Its main goals are to combat greenwashing, help investors make informed choices, and channel finance toward sustainable goals by standardizing disclosures on websites, in prospectuses, and annual reports.

Published in EU Official Journal: https://eur-lex.europa.eu/eli/reg/2019/2088/oj/eng

Penalties

SFDR doesn't have a single EU-wide penalty system, but firms must treat SFDR compliance seriously. Non-compliance leads to enforcement by national regulators (NCAs), resulting in varied penalties like significant fines, reputational damage, "greenwashing" accusations, and legal actions with tougher stances expected as regulators focus on misleading ESG claims and insufficient documentation.

INSIGHTS

KPMG: What is SFDR?

PwC Swirzerland: Aug. 27, 2020 - Sustainable Finance Disclosure Regulation (SFDR)

Société Générale Securities Services: Oct. 14, 2025 - Sustainable Finance Disclosure Regulation (SFDR)

NOW Insight: Impacts to the Hospitality Industry

SFDR impacts the hospitality industry by pushing investors and operators towards greater ESG (Environmental, Social, Governance) transparency. It drives demand for sustainable assets, influencing capital flows, and increasing pressure for verifiable green practices.

Ultimately, it affects property valuations and financing costs for hotels, restaurants, and travel platforms. It forces compliance with detailed disclosures, making it harder to "greenwash" and easier for investors to compare sustainability claims, shifting investment towards truly sustainable or decarbonizing properties.

EU Whistleblowers Directive +

EU WHISTLEBLOWING DIRECTIVE Directive (EU) 2019/1937

Adopted
Oct. 23, 2019

Published
Nov. 26, 2019

Enforced
Dec. 16, 2019

Transposed in EU Member States
Dec. 17, 2021

Applied in EU Member States
Jul. 2024

The EU Whistleblowing Directive is a European Union (EU) legislation aimed at providing high-level, consistent protection for whistleblowers, individuals who report information they acquired in a work-related context on breaches of EU law. It aims to encourage reporting of wrongdoing and safeguarding whistleblowers' freedom of expression.

Published in EU Official Journal: https://eur-lex.europa.eu/eli/dir/2019/1937/oj/eng

Whistleblowing Platforms

The European Commission has established its own anonymous whistleblower tools for antitrust, the AI Act, the Digital Services Act (DSA), and the Digital Markets Act (DMA).

While the Directive mandates confidential reporting, several EU countries have gone further to explicitly permit or require that organizations and public authorities allow anonymous whistleblowing platforms.

Penalties

Vary by Member State and designed to be effective, proportionate, and dissuasive for companies that hinder reporting or retaliate against whistleblowers.

Target failures to create reporting channels, obstructing reports, and retaliation against whistleblowers
Fines potentially reaching Euro tens of thousands for individuals and over €100,000 for companies,
Potential GDPR fines and civil/criminal liability for severe breaches.
Penalties can include imprisonment for knowingly false reports, while companies face financial sanctions, operational disruptions, and reputational damage.

NOTE: European Commission is actively monitoring compliance, with significant fines already being handed out to countries and organizations that fail to comply. Focus is shifting to how well these systems are implemented and whether they truly protect whistleblowers, not just that they exist. This aligns with broader efforts to protect whistleblowers from "Strategic Lawsuits Against Public Participation" (SLAPPs).

INSIGHTS

PwC Switzerland: EU Whistleblowing Directive

EU Whistleblower Center: EU Whistleblowing Directive

Bird & Bird: EU Whistleblowing Directive

NOW Insight - Impacts to the Hospitality Industry

Significantly impacts the hospitality industry, especially those with 50 or more employees. It requires them to create secure, confidential channels for staff to report EU law breaches of sustainability rules, fraud, health/safety violations, or unfair labour.

Companies should set up internal channels that meet Directive standards for confidentiality and accessibility, train staff on the process and their rights, ensure existing HR or compliance processes can handle whistleblowing reports effectively and make it safe for employees to speak up about any health, safety, financial and sustainability irregularity issues.

Supply Chain & Products

EU Corporate Sustainability Due Diligence Directive (CSDDD) +

EU CORPORATE SUSTAINABILITY DUE DILIGENCE DIRECTIVE (CSDDD) Directive 2024/1760

Adopted
May 24, 2024

Published
Dec. 16, 2022

Enforced
Jul. 25, 2024

Transpose in EU Member States Deadline
Jul. 26, 2026 Delayed to
Jul. 26, 2027

Applied in EU Member States:
2027, 2028, 2029

The CSDDD is a European Union (EU) legislation designed to foster sustainable and responsible corporate behavior, integrating human rights and environmental considerations into companies' operations and governance. It will require large EU companies and non-EU companies selling in the EU, to integrate due diligence into their management systems, identify adverse human rights and environmental impacts in their operations, subsidiaries and global supply chain to prevent or mitigate them, assess effectiveness, communicate findings, and provide remediation. It covers the entire value chain, from raw material extraction and manufacturing to transportation and distribution.

Published in European Union Official Journal: https://eur-lex.europa.eu/eli/dir/2024/1760/oj/eng

Fines and Penalties

Strict penalties for non-compliance that vary by EU Member State and designed to be effective, proportionate, and dissuasive.

Fines up to 5% of a company's net worldwide turnover
Public disclosure ("naming and shaming")
Civil liability for damages to victims (with potential for collective redress)
Large fines and criminal sanctions for severe breaches ie. Up to 5 yrs imprisonment in France for directors failing assurance or audit obstructing (lacking 3rd party audit by an accredited Certification Body)
Exclusion from public contracts

Switzerland's Regulatory Alignment

Swiss companies that have subsidiaries or branches in the EU are expected to comply with the CSDDD.

Switzerland currently has specific, limited due diligence rules on conflict minerals and child labor enforced in 2022.

The Federal Council has recognized that stricter EU rules will require "re-alignment with EU’s CSDDD" to ensure the competitiveness of Swiss companies and avoid legal discrepancies.

Penalties

Fines may be imposed for failing to make the required reports, making false statements in the reports, and failing to comply with the legal obligation to retain and document the reports.

Criminal Fines for Individuals: According to Art. 325ter of the Swiss Criminal Code (SCC), individuals (such as board members) responsible for preparing reports who wilfully violate the obligations are subject to fines of up to CHF 100,000.
Negligent Breaches: If the breach of reporting obligations is due to negligence rather than intent, the maximum fine is reduced to CHF 50,000.

INSIGHTS

PwC SWITZERLAND: Feb. 24, 2025 - CSDDD: A game changer for your supply chain

CDP INSIGHT GROUP: CSDD: Corporate Sustainability Due Diligence Directive

DELOITTE: CSDDD: Corporate Sustainability Due Diligence Directive

Omnibus I: Clarity on the future of the CSRD and CSDDD

NOW Insight: Impacts to the Hospitality Industry

CSDDD significantly impacts the hospitality industry. Companies must prepare for a significant increase in due diligence obligations focused on human rights and environmental impacts throughout their value chain.

This will require data transparency, and potentially influencing smaller hotel operators to comply with demands from major clients, impacting everything from energy use to fair labour practices.

EU Ecodesign for Sustainable Products Regulation (ESPR) +

EU ECODESIGN FOR SUSTAINABLE PRODUCTS REGULATION (ESPR) Regulation (EU) 2024/1781

Adopted
Jun. 2024

Published
Jun. 28, 2024

Enforced & Applied in EU Member States
Jul. 18, 2024

The ESPR is a European Union (EU) legislation that established a framework for sustainability product rules, enhancing the existing Ecodesign Directive (2009/125/EC) to cover more products, introduce digital passports, and align with circular economy goals, while also linking to consumer protection via the Representative Actions Directive.

Published in EU Official Journal: https://eur-lex.europa.eu/eli/reg/2024/1781/oj/eng

Penalties

Vary by Member State and designed to be effective, proportionate, and dissuasive.

Heavy fines that consider the nature, gravity, and duration of the infringement, the economic benefits derived, and the environmental damage.
Non-compliant products can be banned or removed access to EU market.
Temporary exclusion from public procurement procedures is a mandated penalty.
Consumers can seek compensation for damages caused by non-compliant products, enabling private enforcement and collective/representative actions against manufacturers and importers.
National authorities may seize or destroy non-compliant products.

Switzerland's Regulatory Alignment

Swiss companies that have subsidiaries or branches in the EU are expected to comply with the ESPR.

Switzerland is progressively aligning its regulatory framework with the EU’s ESPR, focusing on Sustainability Reporting, Due Diligence Reporting, Packaging Ordinance (VerpV) and Digital Product Passport (DPP). The Federal Council requires these reports to be approved by the board of directors and submitted to a shareholder vote (Swiss law (Art. 964a-c CO).

Penalties

Fines may be imposed for failing to make the required reports, making false statements in the reports, and failing to comply with the legal obligation to retain and document the reports.

Criminal Fines for Individuals: According to Art. 325ter of the Swiss Criminal Code (SCC), individuals (such as board members) responsible for preparing reports who wilfully violate the obligations are subject to fines of up to CHF 100,000.
Negligent Breaches: If the breach of reporting obligations is due to negligence rather than intent, the maximum fine is reduced to CHF 50,000.

INSIGHTS

SGS: Jul. 3, 2025 - How will the EU ESPR & DPP impact consumer product markets

Greenly: Sept. 3, 2025 - What is the Ecodesign for Sustainable Products Regulation (ESPR)?

ECOS: Jan. 15, 2025 - Ecodesign: The EU’s journey to sustainable products begins now

NOW Insight - Impacts to the Hospitality Industry

ESPR indirectly impacts the hospitality businesses as large buyers and users of these goods.

Companies should audit their supply chain to understand where current products fall under ESPR rules, prioritize suppliers offering products meeting verifiable durability, repair, and circularity standards. Hotels should align with ESPR goals and focus on reducing waste, water and energy use, and plan to use and provide information from Digital Product Passports.

EU Deforestation Regulation (EUDR) +

EU DEFORESTATION REGULATION (EUDR) Regulation (EU) 2023/1115

Adopted
May 2023

Postponed & Simplified
Dec. 17, 2025

Published
Dec. 23, 2025

Enforced & Applied
Dec. 30, 2026 (L&M Operator)
Jun. 30, 2027 (S&Micro Operator)

The EUDR is a European Union (EU) legislation aims to ensure that products sold in the EU are not sourced from deforested land with the goal to reduce the EU's contribution to global deforestation and forest degradation, cutting emissions and preserving biodiversity.

Published in EU Official Journal: https://eur-lex.europa.eu/eli/reg/2023/1115/oj/eng

Penalties

Vary by Member State and designed to be effective, proportionate, and dissuasive.

Fines up to 4% of a company's total EU turnover
Confiscation of non-compliant products or related revenues
Temporary bans from the EU market
Exclusion from public procurement/funding
Public disclosure of infringements for severe cases
Potential personal liability for directors under national laws

Switzerland's Regulatory Alignment

Swiss companies that have subsidiaries or branches in the EU will have to comply with the EUDR.

Switzerland is updating its Ordinance on Placing Timber and Wood Products on the Market (Timber Trade Ordinance - TTO), and environmental laws to match strict EU standards, requiring due diligence and traceability to ensure that products sold in Switzerland meet the same "deforestation-free" standards required for the EU market. Regulations cover both legal and illegal deforestation. Swiss companies, particularly those exporting to the EU, must implement rigorous supply chain tracking and due diligence.

INSIGHTS

KPMG: EUDR and deforestation: How Swiss businesses can prepare for EUDR compliance

PwC Switzerland: Mar. 3, 2025 – EUDR Regulation on Deforestation-free Products

Deloitte: The European Union Deforestation Regulation (EUDR)

NOW Insight - Impacts to the Hospitality Industry

EUDR significantly impacts the hospitality industry. The supply chain is scrutinised, requiring due diligence & traceability, including precise geolocation of production plots to prove no deforestation occurred after 2020.

Companies are required to prove that products used in their operations are deforestation-free and sourced legally from their country of origin, focusing on geolocation data to trace the origin of key commodities (cattle, soy, cocoa, coffee, palm oil, rubber, wood) and their derivatives, including items like wooden furniture, coffee, and meat.

This affects procurement, requiring new processes for vetting suppliers. Companies will need to select compliant suppliers who can provide concrete evidence, shifting responsibility to those placing products on the EU market.

Climate & Environment

European Climate Law +

EUROPEAN CLIMATE LAW Regulations (EU) 2021/1999

Adopted
Jun. 30, 2021

Published
Jul. 9, 2021

Enforced
Jul. 29, 2021

Applied in EU Member States
Jul. 29, 2021

European Climate Law legislates the goal of the European Green Deal for Europe’s economy and society to become climate-neutral by 2050, which means achieving Net Zero GHG emissions for EU Member States.

The law compels businesses to integrate sustainability into their core operations and sets the intermediate target of reducing net greenhouse gas (GHG) emissions by 55% reduction by 2030, 90% reduction by 2040, negative emissions by 2050. In June 2025, a new proposal to amend the European Climate Law encourage reliance on carbon removal technologies (such as BECCS and DACCS) and permit carbon offsetting to reach the EU greenhouse gas emission reduction targets.

Published in EU Official Journal: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32021R1119

Penalties

There are significant penalties to be imposed on individuals and companies to create stronger deterrents across the EU for environmental and sustainability violations.

Major fines (3 to 5% of global turnover or €24 to €40 million for companies) plus environmental restoration
Exclusion from public funding
Permit withdrawal
Prison sentences (up to 10 years for severe offenses)

Switzerland's Regulatory Alignment

The revised Swiss CO2 Act (enforced Jan. 1, 2025) and the Climate and Innovation Act (CIA) were amended to align with the European Union's climate objectives, particularly the mandatory targets set out in the European Climate Law and the "Fit for 55" package.

INSIGHTS

MORGAN LEWIS: Jan. 7, 2026 - 2040 EU Climate Target and Related EU Climate Policy Developments

CARBON GAP: Oct. 26, 2025 - EU Climate Law (ECL)

STIBBE: Mar. 2025 - The European Climate Law Explained

NOW Insight: Impacts to Hosptiality Industry

The European Climate Law significantly impacts the hospitality industry. Companies should audit operations and review baselines, invest in ^*green tech, ensure all claims are backed by robust, science-based evidence audited by an independent, accredited Certification Body, and advance a Net Zero Plan that imaximise carbon reduction (55% reduction by 2030, 90% reduction by 2040, and net-zero by 2050) in tandem with offsetting with high-quality carbon credits.

^* Tools, products, and processes designed to minimize human impact on the environment, promote sustainability, and reduce carbon emissions.

EU Carbon Border Adjustment Mechanism (CBAM) +

EU CARBON BORDER ADJUSTMENT MECHANISM (CBAM) Regulation (EU) 2023/956

Adopted
Apr. 18, 2023

Published
Oct. 8, 2025

Transition Phase Began
Oct. 2023

Definitive Implementation Phase
Jan. 1, 2026

The Carbon Border Adjustment Mechanism (CBAM) is a European Union (EU) legislation and climate policy that places a carbon tariff on the carbon emitted during the production of carbon-intensive products (such as iron and steel, cement, fertilizers, aluminium, electricity and hydrogen ) imported to the European Union, and encourage cleaner industrial production in non-EU countries. It also prevents "carbon leakage" where companies move production to countries with weaker climate rules.

CBAM ‘s transitional phase of 2023 to 2025 is aligned with the phase-out of free allowances under the EU Emissions Trading System (ETS) to support the decarbonisation of EU industry. The EU ETS is the world’s first and largest "cap-and-trade" carbon market, launched in 2005 to reduce greenhouse gas emissions. It sets a legal limit on emissions for power, industry, and aviation sectors, requiring companies to buy allowances for each tonne of CO2 emitted, covering ~40% of the EU's total emissions.

Published in EU Official Journal: https://eur-lex.europa.eu/eli/reg/2025/2083/oj/eng

Penalties

Penalties are designed to ensure compliance with the CBAM regulations and to prevent carbon emissions being shifted to low-regulation markets.

Penalty for unreported emissions during Transitional Phase (ending 2025): Between €10 and €50 per tonne of emissions that are not reported accurately.
Penalty for unreported emissions during Definitive Implementation Phase (starting Jan. 1, 2026): Significant fines linked to the EU ETS price (€100+/tonne) for failing to surrender certificates, with potential for persistent non-compliers to be barred from the EU market, alongside domestic penalties set by member states.
Penalty for missing, incorrect, or incomplete CBAM reports: The National Competent Authority (NCA) may initiate a correction procedure, which allows reporting declarants to rectify potential errors.
Penalty for failing to surrender sufficient CBAM certificates: Declarants will be liable to pay a penalty identical to the penalty under the EU ETS applicable in the year of importation of the goods.

Switzerland's Regulatory Alignment

Swiss companies that have subsidiaries or branches in the EU are expected to comply with the CBAM. ESPR. or importing non-Swiss materials into the EU must comply with CBAM reporting obligations.

Switzerland is currently exempt from the EU Carbon Border Adjustment Mechanism (CBAM) due to its Emissions Trading System (ETS) being linked with the EU's since 2020. This exemption is because Swiss industries pay a comparable carbon price under the linked Swiss-EU ETS, goods originating from Switzerland are not subject to the EU CBAM. Despite the exemption, Swiss companies operating within the EU or importing non-Swiss materials into the EU must still comply with CBAM reporting obligations.

Switzerland’s Parliament approved a new CO2 Act in March 2024 (effective Jan 1, 2025) to align with the EU’s approach to reduce the free allocation of emission allowances and 2030 targets.

The Swiss electorate supported the broader "Climate and Innovation Act" in June 2023, confirming the national goal of carbon neutrality by 2050 and supporting the shift away from fossil fuels.

The Swiss Federal Council has decided against a separate Swiss CBAM, citing high economic costs, but will review this decision in mid-2026 based on EU developments. While no immediate Swiss equivalent is planned, the ongoing alignment of the Swiss ETS ensures that Swiss products remain competitive within the EU market by meeting equivalent carbon pricing standards.

The Swiss ETS is a cap-and-trade system launched in 2013, regulating greenhouse gas emissions for large, industrial, and aviation sectors in Switzerland. It forces companies to pay for emissions bpolluter pays), requires them to hold allowances for their emissions, and has been linked with the EU ETS since 2020, allowing for trading between the systems.

INSIGHTS

PwC SWITZERLAND: The Carbon Border Adjustment Mechanism

KPMG: Navigating the EU Carbon Border Adjustment Mechanism (CBAM)

WORLD ECONOMIC FORUM: Dec 15, 2025 - How the EU's CBAM will impact the business and carbon pricing

INTL MONETARY FUND (eLibrary): Nov 5, 2025 - Implications for Member States and Trading Partners

EU Industrial Emissions Directive (IED) +

EU INDUSTRIAL EMISSIONS DIRECTIVE (IED) Directive (EU) 2010/75

Adopted
Apr. 12, 2024

Published
Jul. 15, 2024

Enforced
Aug. 4, 2024

Transpose in EU Member States Deadline:
Jul. 1, 2026

Apply in EU Member States:
2030 - 2032

IED is a European Union (EU) legislation designed to prevent and control pollution from large industrial installations and intensive livestock farming. It aims to reduce harmful emissions to air, water, and soil to achieve a zero-pollution, climate-neutral economy by 2050. Focuses on preventing and controlling pollution from industrial activities.

Published in EU Official Journal: https://eur-lex.europa.eu/eli/dir/2010/75/oj/eng

Penalties

Vary by Member State and designed to be effective, proportionate, and dissuasive.

Maximum fines of at least 3% of the operator's annual EU turnover plus Member States are required to establish a system of penalties to include further administrative fines.
Individuals to seek compensation for damages to their health caused by violations of national rules implementing the IED.
Suspension of operations.

Switzerland's Regulatory Alignment

Swiss companies that have subsidiaries or branches in the EU must comply with IED.

Exporting or importing non-Swiss materials into the EU must comply with CBAM reporting obligations.

Switzerland has closely aligned its environmental regulations with the EU Industrial Emissions Directive (IED) and linking its Emissions Trading System (ETS) with the EU's on January 1, 2020. This partnership ensures mutual recognition of allowances, a level playing field for companies, and, as of 2024, daily registry transfers.

While not directly adopting all EU law, Switzerland ensures its regulations for industrial emissions are compatible, allowing for seamless trading and similar emission reduction targets.

INSIGHTS

KPMG: Jan. 13, 2025 - IED: First legislative package to implement the EU directive is available

European Environmental Bureau: Aug. 4, 2024 - Revised Industrial Emissions Directive and Regulation

Nater & Partners: Apr. 29, 2024 - European Union Industrial Emissions Directive

NOW Insight: Impacts to Hospitality Industry

IED indirectly impacts the hospitality industry by raising overall environmental standards, pushing for energy/resource efficiency (water, chemicals), and mandating 'transformation plans' for sustainability.

This means that hospitality companies must innovate and invest in better tech (like EMAS systems) to reduce emissions, use less water/energy, manage waste better, and comply with stricter permitting, or risk higher fines and operational suspension, driving a shift towards greener, circular practices.

EU Batteries Regulation +

EU BATTERIES REGULATION Regulation (EU) 2023/1542

The Batteries Regulation is a European Union (EU) legislation that establishes rules for sustainable batteries, covering their lifecycle and environmental impact. It is designed to promote a circular economy and enhance environmental safety, including strict rules on recycling, material recovery, and carbon footprint.

Adopted
Jun. 14, 2023

Published
Jun. 28, 2023

Enforced
Aug 17, 2023

Applied in EU Member States:
General rules – Feb. 18, 2024
Waste Management – Aug. 2025
Digital Battery Passports – Feb. 2027

Published in EU Official Journal: https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng

Penalties

Vary by Member State and designed to be effective, proportionate, and dissuasive.

Significant fines, potentially up to €100,000 per breach or even a percentage of annual revenue
Marketing and sales bans for products failing to meet requirements, such as lacking valid registration or compliance documentation

Switzerland's Regulatory Alignment

Swiss companies that have subsidiaries or branches in the EU must comply with the EU Battery Regulation.

Switzerland is aligning with the EU Battery Regulation by updating the Swiss Ordinance on the Reduction of Risks linked to Chemical Products (ORRChem).

Swiss regulations will mirror EU requirements for carbon footprint declaration, recycled content, and due diligence for cobalt, graphite, lithium, and nickel, starting in phases from August 2025. From February 18, 2027, batteries for light means of transport (LMT), electric vehicles, and industrial applications (>2 kWh) in Switzerland must have a digital passport for traceability.

Switzerland continues to manage robust, independent, or, in some cases, compatible, collection and recycling systems, similar to the EU’s Extended Producer Responsibility (EPR) model.

INSIGHTS

Brown & Jacobson: Jul. 22, 2025 - Compliance obligations under the EU Batteries Regulation

Bird & Bird: Sept. 24, 2024 - Due Diligence Policy Obligations under the new EU Batteries Regulation

NOW Insight: Impacts for Hospitality Industry

Significantly impacts the hospitality industry by increasing demands for sustainable, traceable, and recyclable batteries in devices (laptops, phones, e-bikes, etc.). This will make it easier for companies to make sustainable choices and access digital information.

Stricter rules mean companies will need efficient systems for collecting and returning used batteries (portable, LMT, industrial) for recycling, possibly through manufacturer take-back schemes. Companies will also have to update purchasing policies to favor compliant, sustainable batteries and devices even if it cost higher initially.

NOW can help. VIEW ... NOW Simplifying Sustainability Offer.

EU Waste Framework Directive (WFD) +

EU WASTE FRAMEWORK DIRECTIVE (WFD) Directive (EU) 2008/98/EC

Adopted
Sept. 9, 2025

Published
Sept 26, 2025

Enforced
Oct .16, 2025

Transposed in EU Member States
Jun. 17, 2027

Applied in EU Member States
Apr .2028

WFD is a European Union (EU) legislation for waste management, promoting the waste hierarchy (prevention, reuse, recycle, recovery, disposal) and principles like the ."polluter pays" and Extended Producer Responsibility (EPR).

A major revision was enforced in October 2025, introducing binding food waste reduction targets (10% in manufacturing, 30% per capita) and new EPR schemes for textiles and footwear, aiming for greater circularity in the EU.

Published in EU Official Journal: https://eur-lex.europa.eu/eli/dir/2025/1892/oj/eng

Penalties

Vary by Member State and designed to be effective, proportionate, and dissuasive.

Penalties are high for improper waste separation, hazardous waste mismanagement and EPR non-compliance for when producers fail to register or pay fees for waste management.
Fines can be severe, such as in the Czech Republic, where failure to comply with food donation obligations can result in fines up to €400,000 (10 million CZK).
Legal action & criminal charges are severe for repeated, or negligent breaches, particularly concerning illegal dumping of hazardous waste which can lead to criminal prosecution.

Switzerland's Regulatory Alignment

Swiss companies that have subsidiaries or branches in the EU must comply with WFD.

Switzerland is actively aligning its waste management and packaging laws with the EU WFD and the newer Regulation (EU) 2025/40 on Packaging and Packaging Waste. The Federal Council is revising the Environmental Protection Act (EPA) to introduce comprehensive Extended Producer Responsibility (EPR), higher recycling rates, and strict, EU-aligned, ecodesign requirements, with new rules likely in effect by 2026.

A new, pending Ordinance (Packaging Waste (VerpV) aims to reduce packaging waste, promote a circular economy, and introduce mandatory take-back and disposal responsibilities for producers.

INSIGHTS

Stibbe: Oct. 23, 2025 - Amendment to the Waste Framework Directive

European Food Banks Federation: Mar. 10, 2025 - Revised Waste Framework Directive: A Milestone for Food Waste Reduction and Food Donation in Europe

NOW Insight: Impacts to Hospitality Industry

WFD impacts the hospitality industry by imposing binding food waste reduction targets (30% per capita by 2030 for restaurants/hotels/food services), mandating measurement & reporting, promoting food donation, and encouraging technological innovation. It requires substantial operational changes for kitchens and a shift from guesswork to data-driven waste management, affecting everything from procurement to guest engagement to meet stricter sustainability goals.

This directive reinforces other EU rules, like those on greenwashing (UCPD/CRD) and corporate reporting (CSRD), pushing the sector towards greater transparency and sustainability.

Reduced waste directly lowers food costs, benefiting the bottom line, especially for SME. It minimizes resource depletion associated with food production and disposal. And it demonstrates commitment to sustainability, appealing to environmentally conscious consumers.

EU Renewable Energy Directive (RED III) +

EU RENEWABLE ENERGY DIRECTIVE (RED III) (EU) 2023/2413

Revision Adopted
Mar. 30, 2023

Published
Oct. 31, 2023

Enforced in EU Member States
Nov. 20, 2023

Appliedin EU Member States
May 21, 2025

The EU Renewable Energy Directive (RED III) is a European Union (EU) legislation designed to significantly raise the EU's binding target for renewable energy from 32% (set in 2018) to 42.5%. This nearly doubles the previous 32% target. The 2023 revision was accelerated to meet the goals of the REPowerEU plan (May 2022) to reduce dependency on Russian fossil fuels. RED III introduces "renewables acceleration areas" with simplified, faster approval procedures.

Published in EU Official Journal: https://eur-lex.europa.eu/eli/dir/2018/2001/oj/eng

Penalties

RED III imposes strict penalties for failing to meet renewable targets by 2030 that will vary by Member State and designed to be effective, proportionate, and dissuasive.

Targetting fuel, €120/GJ will be charge for non-compliance with RFNBO mandates, potential fines of €17,000/t for e-SAF, and legal actions/financial sanctions against member states failing to transpose directives.
For transport fuel suppliers, a penalty of €120 per gigajoule (GJ) is applied to obligated companies failing to meet targets for renewable fuels of non-biological origin (RFNBOs), such as green hydrogen, which rise to 2.5% in 2034 and 8% in 2040.
For compliance and reporting, companies must maintain rigorous, verified documentation for the entire chain of custody for biofuels. Stricter, more granular guarantees of origin (GO) with 1 MWh standards are now required to prevent fraud.

Switzerland's Regulatory Alignment

Swiss companies that have subsidiaries or branches in the EU must comply with RED.

Switzerland is rapidly aligning its energy regulations with the EU by accelerating renewable expansion and enhancing the security of supply with the Swiss Federal Act on a Secure Electricity Supply from Renewable Energies (approved in June 2024). It is commonly known as Mantelerlass and focuses on increasing domestic production from solar, wind, and hydropower, and easing planning constraints for renewable projects to meet 2050 climate goals and increase winter energy production.

INSIGHTS

INTL ENERGY AGENCY: Sept. 5, 2025 - Renewable Energy Directive III (RED III) - GHG threshold

CARBON GAP: Renewable Energy Directive (RED)

CLIMATE CHANGE ADVISORY COUNCIL: EU's Recast Renewable Energy Directive (RED III)

NOW Insight: Impacts to Hospitality Industry

RED III indirectly impacts the hospitality industry by accelerating its transition to green energy, mandating higher renewable usage and energy efficiency. Increased green energy mandates will require hotels to upgrade to more energy-efficient lighting and HVAC systems, moving away from fossil fuels. Infrastructure investment is significant for energy-efficient retrofits, such as implementing smart room technologies and integrating renewable energy sources. While initial investment is high, these measures aim to reduce long-term operational costs through decreased energy consumption and result in savings. There is increased importance of science-based certifications schemes with audits by an independent, accredited Certification Body

EU Water Framework Directive (WFD) +

EU WATER FRAMEWORK DIRECTIVE (WFD) Directive 2000/60/EC

Adopted
Oct. 2000

Published
Sept 26, 2025

Enforced
Dec 22, 2000

Transposed in EU Member States
Jun. 17, 2027

Applied in EU Member States
Apr. 2028

The EU Water Framework Directive (WFD) is a European Union (EU) legislation to ensure all surface and groundwaters achieve "good status" (ecological and chemical) by 2027.

It operates in six-year planning cycles and we are currently in the 3rd Management Cycle (2022–2027), which involves the implementation of 3rd River Basin Management Plans (RBMPs), program of measures to restore ecosystems and reduce pollution, and covers rivers, lakes, groundwater and coastal waters.

Published in EU Official Journal: https://eur-lex.europa.eu/eli/dir/2000/60/oj/eng

Penalties

Vary by Member State and designed to be effective, proportionate, and dissuasive.

The European Commission monitors compliance and can refer Member States have been referred to the Court of Justice of the European Union for failing to meet standards or update plans.
Criminal liability for severe environmental damage to water quality caused by gross negligence and can lead to prosecutions.

Switzerland's Regulatory Alignment

Swiss companies that have subsidiaries or branches in the EU must comply with WFD.

Switzerland aligns significantly with the EU Water Framework Directive (WFD), focusing on high-level water protection through its Federal Act on the Protection of Water (Water Protection Act / WPA) and Ordinance (WPO). Key efforts include, upgrading wastewater treatment plants to remove micropollutants by 2040, monitoring priority substances, and protecting groundwater.

INSIGHTS

WWF: The EU Water Framework Directive

OECD: Implementing Water Economics in the EU Water Framework Directive

NOW Insight: Impacts to Hospitality Industry

WWD impacts the hospitality industry, demanding strict water management, reduced chemical use, and waste management. It enforces the "polluter pays" principle, meaning higher, full-cost recovery tariffs for water usage and potential, more expensive, wastewater treatment.

Hotels must adopt water-saving technologies in rooms, laundry, and kitchens to reduce their, at times, heavy impact on local water sources. Hotels are facing increased requirements to monitor, report, and manage their water footprint as part of regional River Basin Management Plans (RBMPs) and compliance is tied to environmental certifications audited by an independent accredited Certification Body.

In the Mediterranean or tourist-heavy regions, strict regulations on water usage for pools, spas, and irrigation are becoming standard to combat scarcity.

EU Packaging And Packaging Waste Regulation (PPWR) +

EU PACKAGING AND PACKAGING WASTE REGULATION (PPWR) (EU) 2025/40

Adopted
Dec. 13, 2025

Published
Jan. 22, 2025

Enforced
Feb. 11, 2025

Applied in EU Member States:
Aug. 12, 2026

Phases of specific targets for
2030, 2035, 2040

The Packaging and Packaging Waste Regulation (PPWR) is a European Union (EU) legislation replacing the previous Directive 94/62/EC to create a more uniform approach to packaging sustainability, with a focus on reduction, reuse, and recycling in phases.

By 2026, limits on per- and polyfluorinated alkyl substances (PFAS) in food-contact packaging. Aug 2026 deadline for general application of PFAS restrictions.

By Aug. 12, 2027 deadline, all packaging must have mandatory harmonized labelling.

By 2028, harmonized labels for material identification and disposal instructions will be mandatory.

By Jan. 1, 2030 deadline, all packaging must be recyclable, Mandatory minimums for post-consumer recycled content in plastic packaging (e.g., 30% for contact-sensitive PET by 2030). Empty space in transport/e-commerce packaging must not exceed 50%. Specific single-use plastic formats will be banned (e.g., mini-bottles for shampoo, sachets for sauces, plastic wrapping for fruit/veg under 1.5 kg). Jan. 1 2030: Design for recycling, 50% empty space rule, minimum recycled plastic content, specific packaging bans.

By 2035, all packaging must be recycled at scale.

By Jan. 1, 2040 deadline, all packaging must have higher recycling targets and 15% reduction in per capita waste.

NOTE: Swiss companies operating within the EU must comply with PPWR.

Published in EU Official Journal: https://eur-lex.europa.eu/eli/reg/2025/40/oj/eng

Penalties

Vary by Member State and designed to be effective, proportionate, and dissuasive.

Producers must register in each Member State and contribute to EPR (Extended Producer Responsibility) schemes, with fees modulated based on the packaging's sustainability (eco-modulation).
Manufacturers must prepare technical documentation and a declaration of conformity, which must be kept for 5–10 years.

Switzerland's Regulatory Alignment

Swiss companies that have subsidiaries or branches in the EU must comply with the PPWR.

Switzerland is aligning with PPWR with the draft Ordinance on Packaging (d-PO) to harmonize with EU standards (mandatory from 2030) for recyclability and material reduction to avoid trade barriers for Swiss exporters.

While adopting core sustainability, recycling, and design-for-recycling principles, the Swiss approach is generally less restrictive, focusing on voluntary, industry-led measures. Switzerland is currently not expected to adopt binding minimum recycled content quotas or strict, universal bans on specific single-use plastic packaging. Due to high performance in voluntary recycling (e.g., PET, glass, paper), the focus is on filling gaps in composite material recovery.

INSIGHTS

ZHAW. Feb. 11, 2025 - EU Packaging and Packaging Waste Regulation (PPWR) enters into force

SGS: Feb. 11, 2025 - EU Issues New Legislation for Packaging and Packaging Waste

ESG SPOTLIGHT: Aug. 15, 2024 - A Guide for the New EU Packaging & Packaging Waste Regulation

NOW Insight: Impacts to Hospitality Industry

PPWR has significant impacts to the hospitality industry and represents a massive shift from disposable, single-use plastic to mandatory reuse, reduction, and recycling targets.

From January 1, 2030, the following single-use plastic packaging is banned in the hospitality sector: Single-use plastic packaging for food and beverages filled and consumed within hotels, restaurants, and cafés. Small, individual single-use sachets, tubs, and trays for condiments, sauces, sugar, and milk creamers. Miniature shampoo, soap, and cosmetic bottles in accommodation, which must be replaced by refillable dispensers. Single-use plastic film used to bundle products at the point of sale.

By Feb. 2027, takeaway businesses must allow customers to use their own containers for food and beverages at no additional cost.

From 2026 to 2030, packaging design and chemical restrictions bans takes effect.

By 2028, takeaway operators must offer customers the option to receive their food or drinks in reusable packaging, within a deposit system, at no additional cost.

By 2030, businesses must ensure a percentage of their packaging is reusable (e.g., for beverage sales, 10% by 2030, rising to 40% by 2040).

There are extensive operational & administrative impacts to restaurants and hotels since they are considered "producers" of the packaging they fill, making them financially responsible for its disposal. EPR fees will be "modulated," meaning hard-to-recycle packaging will incur higher costs. Standardized, mandatory labels must be used to indicate material composition and disposal methods. Businesses must maintain technical documentation and an EU Declaration of Conformity to prove packaging compliance, to be retained for 5-10 years.

Eu Sustainable Use Of Pesticide Directive (Supd Or Sud) +

EU SUSTAINABLE USE OF PESTICIDE DIRECTIVE (SUPD or SUD) (2009/128/EC)

Adopted & Published
Oct. 21, 2009

Enforced
Nov. 25, 2009

Transposed Deadline
Nov. 26, 2011

Apply EU Member States:
2011/201

Mandatory IPM implementation:
2014

Harmonised Risk Indicators Update:
2019/2021

The EU Sustainable Use of Pesticide Directive (SUPD or SUD) aims to reduce risks and impacts of pesticide use on human health and the environment, while promoting Integrated Pest Management (IPM). It mandates National Action Plans, training for operators, and inspection of equipment.

The EU aims to strengthen the SUD to support "Farm to Fork" strategy goals for reducing pesticide risks.

NOTE: In June 2022, the EU Commission adopted the Sustainable Use of Plant Protection Products Regulation, aiming to reduce chemical pesticide use and risk by 50% by 2030. It was withdrawn on Feb. 4, 2024, due to intense protests by farmers across Europe and a rejection of the proposal by the European Parliament, indicting the need for a new, more collaborative approach with farmers to balance environmental goals with economic reality. However, the original 2009 Sustainable Use of Pesticide Directive remains in force. Member States are still required to have National Action Plans (NAPs), but without the binding 50% reduction targets that were proposed in the new regulation.

Published in EU Official Journal:: https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:309:0071:0086:en:PDF

Penalties

Fines or imprisonment penalties vary by Member State and designed to be effective, proportionate, and dissuasive. Penalties may apply for failing to adhere to mandatory Integrated Pest Management (IPM), improper training, failing to test application equipment, or using pesticides in prohibited "sensitive areas".

Examples of Penalties in France: Up to €750,000 for specific violations, such as fraudulent, counterfeit, or prohibited use of products. Up to 7 years imprisonment for severe cases. €150,000 for unlawful use of pesticides.

Switzerland's Regulatory Alignment

Swiss companies that have subsidiaries or branches in the EU must comply with SUPD.

Switzerland aligns an equivalent legislation on hazard-based pesticide driven by the Plant Protection Products Ordinance (PSMV), the Federal Act on the Protection of Waters, and mandatory Proof of Ecological Performance (PEP), which mandate integrated pest management (IPM), reduction targets, and restricted usage of hazardous substances to protect human health and the environment.

Swiss approval procedures can take up to 5+ years, often slower than the EU, partly due to resource constraints, causing delays in accessing modern, eco-friendly pesticides.

A Mutual Recognition Agreement (MRA) exists for biocidal products between the Switzerland and the EU. Switzerland is included in "Zone B – Centre" under the EU zonal system, aiding in assessment convergence.

The EU and Switzerland have strengthened ties and moving towards a closer, formalized alignment covering the entire food chain, requiring ratification.

INSIGHTS

PCS Agriculture: Sustainable Use of Pesticide Directive

Fairway: Directive on the Sustainable use of Pesticid

European Environmental Bureau: Revision on the Sustainable Use of Pesticide Directive

NOW Insight: Impact to Hospitality Industry

SUPD (or SUD) impacts the hospitality industry, driven by the requirements of Integrated Pest Management (IPM), demands for safer, non-chemical alternatives, and the broader push for credible sustainability certifications, and sustainable procurement in food sourcing and landscaping. It is influencing companies to scrutinise their food supply chains and engage in more sustainable, traceable, and eco-friendly purchasing.

Hotels, resorts, and restaurants with outdoor spaces are under pressure to reduce pesticide use in sensitive areas, requiring alternative landscaping and maintenance techniques.

SUPD (or SUD) encourage the industry to demand food products with lower pesticide residues, which sets supplier and food sourcing standards and drives higher demand for organic or IPM-certified ingredients. SUP necessitates better training for personnel handling pest control, promoting certified, low-risk, or biological pest control methods, and mandates safe storage and application, which affects how pesticides are handled within the facility.

Q1 2026 Update - Swiss Sustainability Framework & Insights +

Switzerland's Sustainability Framework is a comprehensive set of Swiss Acts, Ordinances and Codes focused on mandatory climate and non-financial reporting, enhancing due diligence in supply chains, promoting broader ESG disclosures and increasing pressure for transparency, and legislation that aim for broader scope and audit requirements.

Switzerland is not a European Union (EU) member and EU directives and regulations cannot mandate any changes to its domestic law. Switzerland maintains its sovereignty when important but market realities of trading with the EU and economic competitiveness mean Swiss companies are forced to align with stricter standards, often adopting them for domestic operations as well to gain a competitive advantage. It will likely affect the economic playing field and impact even those Swiss companies without subsidiaries or branches abroad because investors, consumers and non-governmental organisations are increasingly demanding detailed and comparable information on ESG. It will also affect SMEs since large companies are increasingly demanding such information.

A Swiss Act (Federal Act or Bundesgesetz) is a legislative instrument passed by the Swiss Federal Assembly that outlines important, legally binding rules subordinate to the Federal Constitution but superior to ordinances, and cover areas like civil and criminal law.

A Swiss ordinance is a legal act issued by the executive branch (Federal Council or departments) to implement, detail, or enforce laws passed by Parliament.

A "Swiss Code" usually refers to the Swiss Code of Obligations, a 1911 federal law (part of the Swiss Civil Code) regulating contract law, commercial transactions, and corporate governance. It governs contractual relationships, company structures (like SA/AG), and financial reporting.

Communications, Reporting & Disclosure

EU
Aligned

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EU Corporate Sustainability Reporting Directive (CSRD) +

EU CORPORATE SUSTAINABILITY REPORTING DIRECTIVE (CSRD) Directive (EU) 2022/246

Adopted
Nov. 28, 2022

Published
Dec. 16, 2022
Enforced
Jan. 5, 2023

Transposed in EU Member States deadline
Jul. 6, 2024

Applied in Phases Report
FY2024 FY2025/2026 FY2027/2028

Omnibus/ Stop-the-Clock transposition delayed to
Dec. 31, 2025

Published in EU Official Journal: https://eur-lex.europa.eu/eli/dir/2022/2464/oj/eng

Penalties

Vary by Member State and designed to be effective, proportionate, and dissuasive for non-compliance.

Heavy financial fines (eg. up to €10M or 5% of global turnover in Germany or France's up to €18,750)
Public disclosure ("naming and shaming")
Criminal sanctions for severe breaches ie. Up to 5 yrs imprisonment in France for failing assurance or obstructing audits (lack 3rd party audit from accredited Certification Body)
Fines and exclusion from public contracts for general non-compliance
Significant reputational damage

The Omnibus Package

Omnibus Package was launched on 26 February 2025 to simplify and increase focus on EU competitiveness by reducing administrative burdens by 25% for all businesses and 35% for SMEs. Modifies CSRD.

Narrowed Scope: CSRD will primarily apply to large companies with over 1,000 employees, reducing the number of directly affected entities.
Delayed Reporting Timelines:
- FY 2024 (due 2025): Large public-interest entities (500+ employees) already subject to previous NFRD.
- FY 2025/2026 (Delayed): Other large companies and listed SMEs were originally set to report, but this is being postponed by the "Stop the Clock" Omnibus proposal, with many moving to FY 2027/2028 (due 2028/2029).
- Non-EU Companies: Must start reporting in 2029 (for FY 2028).
Omnibus Package has a broad reach. Despite scope changes, the interconnectedness with EU partners means many non-EU companies (like Swiss firms) must still comply or adapt to meet supply chain requirements. While SMEs are not directly in scope, they will face significant indirect pressure from large partners to provide data and prove their credible sustainability credentials.

Switzerland's Regulatory Alignment

Swiss Publication Platform: Code of Obligations - Transparency on Non-Financial Matters (Articles 964a-c).

Penalties

Fines may be imposed for failing to make the required reports, making false statements in the reports, and failing to comply with the legal obligation to retain and document the reports.

Criminal Fines for Individuals: According to Art. 325ter of the Swiss Criminal Code (SCC), individuals (such as board members) responsible for preparing reports who wilfully violate the obligations are subject to fines of up to CHF 100,000.
Negligent Breaches: If the breach of reporting obligations is due to negligence rather than intent, the maximum fine is reduced to CHF 50,000.
Corporate Liability: While the company itself cannot be directly fined for violations of Art. 325ter SCC, if the breach cannot be attributed to a specific person due to inadequate organization, a fine of up to CHF 5 million can be imposed on the company under Article 102 of the Criminal Code.

INSIGHTS

NOW Insight: Impacts to the Hospitality Industry

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EU Empowering Consumers for the Green Transition Directive (ECGTD) +

EU EMPOWERING CONSUMERS FOR THE GREEN TRANSITION DIRECTIVE (ECGTD) Directive (EU) 2024/825

Adopted
Feb. 28, 2024

Published
Feb. 28, 2024

Enforced
Mar. 27, 2026

Transpose in EU Member States
Mar. 27, 2026

Apply rules in EU Member States
Sept. 27, 2026

Published in EU Official Journal: https://eur-lex.europa.eu/eli/dir/2024/825/oj/eng

Penalties

Vary by Member State and designed to be effective, proportionate, and dissuasive for non-compliance.

Substantial fines up to 4% of annual turnover
Confiscation of illicit revenue gained from the misleading product or claims.
Public exposure
Bans from the market enforced by national bodies leveraging Unfair Commercial Practices Directive (UCPD) powers
Temporary exclusion from public tenders and access to public funds (up to 12 months)
Public disclosure of the violations ("naming and shaming")

Switzerland's Regulatory Alignment

Swiss Publication Platform: Federal Law on Unfair Competition Act (Articles 964a-c)

Penalties

The Swiss UCA relies on a mix of civil and criminal penalties for companies:

Civil Liability: Competitors, customers, and consumer protection organizations can file lawsuits for injunctive relief or to have the advertising removed (Art. 9 UCA).
Criminal Liability: Under Art. 23 UCA, intentionally engaging in greenwashing can result in fines up to CHF 540,000.
Corporate Fine: If a person cannot be held directly responsible due to inadequate organization, the company itself can face a fine of up to CHF 5 million.

NOTE: The State Secretariat for Economic Affairs (SECO) can take action, and environmental claims can be reviewed by the Swiss Commission for Fair Trading (SLK).

INSIGHTS

NOW Insight: Impacts to the Hospitality Industry

ECGTD will seriously impact hospitality companies in the EU and abroad that make any sustainability related claims to an EU consumer.

Companies will have to prepare for scrutiny. ECGTD means

Any sustainability related terms (such as local, green, sustainable, conscious, climate friendly, ++) and claims (such as carbon reduction, carbon neutral, Net Zero, plant-based, regenerative, zero waste, ++) and communications or storytelling must be backed by robust, science-based evidence that is credibly audited by an independent, accredited Certification Body.
Product lifespan and repairability for hotel items (linens, furniture, appliances, etc) should be checked.
Communication should be accessible to stakeholders in at least one official language of the country where the information is visible.

VIEW the NOW Sustainability Reporting Tool and how Force for Good hotels use the tool to communicate with accountability, compliance and transparency to engage stakeholders:

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EU Whistleblowers Directive +

EU WHISTLEBLOWING DIRECTIVE Directive (EU) 2019/1937

Adopted
Oct. 23, 2019

Published
Nov. 26, 2019

Enforced
Dec. 16, 2019

Transposed in EU Member States
Dec. 17, 2021

Applied in EU Member States
Jul. 2024

Published in EU Official Journal: https://eur-lex.europa.eu/eli/dir/2019/1937/oj/eng

Whistleblowing Platforms

Penalties

Vary by Member State and designed to be effective, proportionate, and dissuasive for companies that hinder reporting or retaliate against whistleblowers.

Target failures to create reporting channels, obstructing reports, and retaliation against whistleblowers
Fines potentially reaching Euro tens of thousands for individuals and over €100,000 for companies,
Potential GDPR fines and civil/criminal liability for severe breaches.
Penalties can include imprisonment for knowingly false reports, while companies face financial sanctions, operational disruptions, and reputational damage.

INSIGHTS

PwC Switzerland: EU Whistleblowing Directive

EU Whistleblower Center: EU Whistleblowing Directive

Bird & Bird: EU Whistleblowing Directive

NOW Insight - Impacts to the Hospitality Industry

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Geneva Whistleblowing Law +

GENEVA WHISTLEBLOWING LAW Officially: RSG B 5 07 (LPLA)

Adopted
Jan. 29, 2021

Published
Jan. 29, 2021

Enforced
Mar. 16, 2022

Key mechanisms validated by Council of State on
Jan. 11, 2023

Switzerland does not have a comprehensive, federal whistleblower protection law since the proposed national legislation was rejected in 2020, leaving whistleblowers without specific legal protections in the private sector. While a Code of Obligations contains general duties of loyalty and good faith for employees, it also prohibits disclosing employer-sensitive information.

The canton of Geneva is leading in adopting the Law on the Protection of Whistleblowers within the State of Geneva (LPLA - Loi sur la protection des lanceurs d’alerte au sein de l’État) which focus on internal protection, preventing damage to the employee, and enforcing administrative, disciplinary, or, if criminal, penal consequences under existing Swiss laws. It protects state employees, municipalities, and public law institutions and universities, who report irregularities (misconduct, corruption, or violations) related to the state's activities based on "reasonable suspicion," and for the public interest.

Other cantons - Basel-Stadt, Bern, Zurich, and Jura – are in the process of developing their own laws. Some Swiss companies are establishing internal reporting channels to comply with the EU’s whistleblower directive.

In the public sector, there is no comprehensive statutory protection for whistleblowers. Instead, it is governed by general Swiss employment law (duty of loyalty), meaning employees must generally report internally first, which can be difficult at times with tiered reporting requirements. The Federal Personnel Act (Article 22a) allows reporting to an external authority if internal reporting fails.

Canton of Geneva Official Publication: https://silgeneve.ch/legis/index.aspx

Whistleblowing Platform

The Swiss Confederation has established an anonymous whistleblower platform. Federal Department of Foreign Affairs (FDFA) Whistleblowing Platform.

Penalties

The Law on the Protection of Whistleblowers within the State of Geneva (LPLA - B 5 07) explicitly prohibits retaliatory measures and guarantees confidentiality. While whistleblowers are not explicitly protected, companies can face significant fines for underlying misconduct (e.g., corruption, data breaches) under criminal law. Intentional breaches of data protection (might be involved in whistleblowing,) can lead to fines for individuals of up to CHF 250,000.

NOTE: The Organisation for Economic Co-operation and Development (OECD) has urged Switzerland to adopt legislation to protect private-sector whistleblowers and increase fines for bribery IN 2024 and 2025. There have been proposals in the Swiss Parliament to legally protect whistleblowing in the private sector and increase penalties.

INSIGHTS

DELLOITE: Apr. 5, 2023: Swiss Whistleblowing Law - what’s the current situation and what should companies consider?

GLOBAL GENEVA: Nov. 15, 2020: Whistleblowing in Switzerland: A Global Compliance Gap

UNIVERSITE DE GENEVE: Whistleblowers

NOW Insight: Impacts to the Hospitality Industry

LPLA impacts hospitality companies in Geneva. Hotels with over 50 employees or international connections must provide internal, confidential, secure reporting channels to prevent risks like fraud, reputational damage, and potential legal penalties. Hotels must ensure that any internal reporting process keeps the identity of the whistleblower and the accused confidential, adhering to data protection laws.

Supply Chain & Products

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EU Corporate Sustainability Due Diligence Directive (CSDDD) +

EU CORPORATE SUSTAINABILITY DUE DILIGENCE DIRECTIVE (CSDDD) Directive 2024/1760

Adopted
May 24, 2024

Published
Dec. 16, 2022

Enforced
Jul. 25, 2024

Transpose in EU Member States Deadline
Jul. 26, 2026 Delayed to
Jul. 26, 2027

Applied in EU Member States:
2027, 2028, 2029

Published in European Union Official Journal: https://eur-lex.europa.eu/eli/dir/2024/1760/oj/eng

Fines and Penalties

Strict penalties for non-compliance that vary by EU Member State and designed to be effective, proportionate, and dissuasive.

Fines up to 5% of a company's net worldwide turnover
Public disclosure ("naming and shaming")
Civil liability for damages to victims (with potential for collective redress)
Large fines and criminal sanctions for severe breaches ie. Up to 5 yrs imprisonment in France for directors failing assurance or audit obstructing (lacking 3rd party audit by an accredited Certification Body)
Exclusion from public contracts

Switzerland's Regulatory Alignment

Penalties

Fines may be imposed for failing to make the required reports, making false statements in the reports, and failing to comply with the legal obligation to retain and document the reports.

Criminal Fines for Individuals: According to Art. 325ter of the Swiss Criminal Code (SCC), individuals (such as board members) responsible for preparing reports who wilfully violate the obligations are subject to fines of up to CHF 100,000.
Negligent Breaches: If the breach of reporting obligations is due to negligence rather than intent, the maximum fine is reduced to CHF 50,000.

INSIGHTS

NOW Insight: Impacts to the Hospitality Industry

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Swiss Ordinance on Due Diligence and Transparency (DDTrO) +

SWISS ORDINANCE ON DUE DILIGENCE & TRANSPARENCY (DDTrO) Swiss Code of Obligations: Articles 964a - 964c for Non-financial Reporting
Articles 964j – 964l for Conflict Minerals and Child Labour

Adopted
Nov. 2020

Published
Jan. 1, 2022

Enforced
Jan. 1, 2022

Applied FY2023
+ first reports published in 2024

The Swiss Ordinance on Due Diligence and Transparency (DDTrO) require Swiss companies to conduct supply chain due diligence regarding conflict minerals (tin, tantalum, tungsten, gold) and child labour. It mandates implementing supply chain policies, traceability systems, and annual reporting to ensure compliance, aimed at mitigating human rights and environmental risks.

Reporting rules on environmental (including climate), social, employee-related issues, human rights and anti-corruption apply to companies with their registered office, head office or principal place of business in Switzerland that offer products or services where there is a reasonable suspicion of child labour in the manufacture of goods or the provision of services.

The only exceptions to child labour due diligence obligations apply to "low-risk companies" and SMEs with 250 full-time equivalent employees, a balance sheet total of CHF 20 million, and a turnover of CHF 40 million.

NOTE: The provisions are currently under revision to align better with the EU Corporate Sustainability Reporting Directive (CSRD), with a potential tightening of rules expected to be finalized in 2026.

Federal Law Publication Platform: https://www.fedlex.admin.ch/eli/cc/2021/847/en

Penalties

All board members of companies subject to reporting requirements may be liable to prosecution. In cases involving child labor and conflict minerals, board members of SMEs may also be considered offenders.

Fines may be imposed for failing to make the required reports, making false statements in the reports, and failing to comply with the legal obligation to retain and document the reports.

Criminal Fines for Individuals: According to Art. 325ter of the Swiss Criminal Code (SCC), individuals (such as board members) responsible for preparing reports who wilfully violate the obligations are subject to fines of up to CHF 100,000.
Negligent Breaches: If the breach of reporting obligations is due to negligence rather than intent, the maximum fine is reduced to CHF 50,000.

INSIGHTS

DELLOITE: Aug. 25, 2023: Illustration of the new non-financial reporting requirements for Swiss companies

Dec. 21, 2022 - Emerging sustainability obligations in the EU and their impact on Swiss (and international) business.

PwC SWITZERLAND: Mar. 2023 - Regulatory Update: ESG Development

Feb. 23, 2022 - Sustainability Reporting and Due Diligence

SIDLEY: Apr. 19, 2023 - Diligence Obligations

NOW Insight: Impacts to the Hospitality Industry

The Swiss DDTrO significantly impacts hospitality companies operating in Switzerland that procure goods or services suspected of being linked to child labour, such as cocoa (chocolates) or electronics (chips) from high-risk conflict regions.

If hotels, restaurants and hospitality suppliers purchase, import or process materials from conflict areas, they must follow specific due diligence and adopt rigorous, risk-based approaches to their overall procurement processes, and implement supply chain monitoring, risk assessment, and transparent reporting to ensure compliance and mitigate reputational risks.

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EU Ecodesign for Sustainable Products Regulation (ESPR) +

EU ECODESIGN FOR SUSTAINABLE PRODUCTS REGULATION (ESPR) Regulation (EU) 2024/1781

Adopted
Jun. 2024

Published
Jun. 28, 2024

Enforced & Applied in EU Member States
Jul. 18, 2024

Published in EU Official Journal: https://eur-lex.europa.eu/eli/reg/2024/1781/oj/eng

Penalties

Vary by Member State and designed to be effective, proportionate, and dissuasive.

Heavy fines that consider the nature, gravity, and duration of the infringement, the economic benefits derived, and the environmental damage.
Non-compliant products can be banned or removed access to EU market.
Temporary exclusion from public procurement procedures is a mandated penalty.
Consumers can seek compensation for damages caused by non-compliant products, enabling private enforcement and collective/representative actions against manufacturers and importers.
National authorities may seize or destroy non-compliant products.

Switzerland's Regulatory Alignment

Penalties

Fines may be imposed for failing to make the required reports, making false statements in the reports, and failing to comply with the legal obligation to retain and document the reports.

Criminal Fines for Individuals: According to Art. 325ter of the Swiss Criminal Code (SCC), individuals (such as board members) responsible for preparing reports who wilfully violate the obligations are subject to fines of up to CHF 100,000.
Negligent Breaches: If the breach of reporting obligations is due to negligence rather than intent, the maximum fine is reduced to CHF 50,000.

INSIGHTS

NOW Insight - Impacts to the Hospitality Industry

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EU Deforestation Regulation (EUDR) +

EU DEFORESTATION REGULATION (EUDR) Regulation (EU) 2023/1115

Adopted
May 2023

Postponed & Simplified
Dec. 17, 2025

Published
Dec. 23, 2025

Enforced & Applied
Dec. 30, 2026 (L&M Operator)
Jun. 30, 2027 (S&Micro Operator)

Published in EU Official Journal: https://eur-lex.europa.eu/eli/reg/2023/1115/oj/eng

Penalties

Vary by Member State and designed to be effective, proportionate, and dissuasive.

Fines up to 4% of a company's total EU turnover
Confiscation of non-compliant products or related revenues
Temporary bans from the EU market
Exclusion from public procurement/funding
Public disclosure of infringements for severe cases
Potential personal liability for directors under national laws

Switzerland's Regulatory Alignment

INSIGHTS

NOW Insight - Impacts to the Hospitality Industry

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Swiss Ordinance on Placing Timber and Wood Products on the Market +

SWISS ORDINANCE ON PLACING TIMBER AND WOOD PRODUCTS ON THE MARKET Ordinance 814.021

Adopted
May 11, 2021

Published
Jan. 1, 2022

Enforced
Jan. 1, 2022

Applied
Jan. 1, 2022

The Ordinance on Placing Timber and Wood Products on the Market (Timber Trade Ordinance - TTO), known in German as the Holzhandelsverordnung (HHV), aim to ensure that only legally harvested timber and timber products are placed on the Swiss market. The TTO apply to products placed on the market after Jan. 1, 2022. The Federal Office for the Environment (FOEN) is responsible for enforcement, primarily targeting importers of large quantities, while cantons monitor domestic forest owners.

It is aligned with the European Union Timber Regulation (EUTR) (Regulation (EU) No 995/2010) which prohibits placing illegally harvested timber or timber products on the EU market. Effective since 2013, it mandates that operators exercise due diligence to ensure legality and requires traders to maintain supply chain records. EUTR will be replaced by the EUDR (Deforestation Regulation) in late 2026.

Federal Law Publication Platform: Ordinance on Placing Timber and Wood Products on the Market (SR 944.021)

Penalties and Violations

Violations of the TTO are treated as criminal offenses under the amended Swiss Environmental Protection Act:

Intentionally placing illegal timber on the market or failing to comply with due diligence obligations can result in a prison sentence of up to three years or a fine.
Wilful violation of the traceability provisions (record-keeping) carries a fine of up to CHF 20,000.
Violations committed through negligence can result in monetary penalties of up to 180 daily penalty units.
The FOEN and cantons are authorized to seize timber or wood products if there are reasonable grounds to suspect they are illegally harvested or traded.

INSIGHTS

Global Traceability: Swiss Timber Regulation and Compliance

Forest Governance & Policy: Swiss Timber Trade Ordinance

NOW Insight: Impacts to the Hospitality Industry

TTO significantly impact the hospitality industry. Swiss companies are required to prove that products used in their operations are legally harvested timber and timber products.

Supply chain is scrutinised, requiring due diligence & traceability. Hotel procurement will require new processes for vetting compliant suppliers who can provide concrete evidence, shifting responsibility to those placing products on the Swiss market.

Climate & Environment

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European Climate Law +

EUROPEAN CLIMATE LAW Regulations (EU) 2021/1999

Adopted
Jun. 30, 2021

Published
Jul. 9, 2021

Enforced
Jul. 29, 2021

Applied in EU Member States
Jul. 29, 2021

Published in EU Official Journal: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32021R1119

Penalties

There are significant penalties to be imposed on individuals and companies to create stronger deterrents across the EU for environmental and sustainability violations.

Major fines (3 to 5% of global turnover or €24 to €40 million for companies) plus environmental restoration
Exclusion from public funding
Permit withdrawal
Prison sentences (up to 10 years for severe offenses)

Switzerland's Regulatory Alignment

INSIGHTS

NOW Insight: Impacts to Hosptiality Industry

^* Tools, products, and processes designed to minimize human impact on the environment, promote sustainability, and reduce carbon emissions.

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Swiss Ordinance on Climate Disclosure +

SWISS ORDINANCE ON CLIMATE DISCLOSURE Article 964a-964c of the Swiss Code of Obligations

Adopted
Nov. 23, 2022

Published
Nov. 23, 2022

Enforced/Applied
Jan. 1, 2024

First Reporting Period
Jan. 1, 2025

The Swiss Ordinance on Climate Disclosures makes the recommendations of the Task Force on Climate-related Financial Disclosures (TCFD) binding for large Swiss companies. It was adopted to improve transparency regarding climate risks and the environmental impact of business activities (double materiality).

The regulation applies to "public interest entities" (publicly traded companies, banks, and insurance companies) that meet specific size criteria: 500 or more full-time positions (on average over two consecutive years) and at least CHF 20 million in total assets OR over CHF 40 million in turnover.

Companies must report on Double Materiality - how climate change affects their business (financial risk) AND how their business impacts the climate. Reports must cover governance, strategy, risk management, and metrics/targets (aligned with TCFD). Transition Plan of in-scope companies must define, disclose, and implement concrete reduction targets for greenhouse gas emissions (including Scope 1, 2, and 3) and explain how they plan to meet them. Reports must be in machine-readable format (e.g., XHTML)

Federal Law Publication Platform: https://www.newsd.admin.ch/newsd/message/attachments/74006.pdf

Penalties

Non-compliance with the reporting obligations is punishable under Article 325ter of the Swiss Criminal Code.

Criminal fines of up to CHF 100,000 can be imposed for intentional, false, or omitted reporting.
Negligent breaches can result in fines of up to CHF 50,000.
The penalty applies to individuals (e.g., board members, executives) responsible for preparing the report.

INSIGHTS

PwC SWITZERLAND: Dec. 13, 2024 - Federal Council opens consultation on amending the ordinance on climate disclosures

CLIMATE CHANGE LAWS OF THE WORLD: Ordinance on Climate Disclosures, made under the Swiss Code of Obligations

NOW Insight: Impacts to the Hospitality Industry

The Swiss Ordinance on Climate Disclosures have a significant impact on large hospitality companies. It mandates reports on climate-related risks, strategies and emissions, and demand transparency on supply chain emissions and climate risk management, requiring compliance or explanation of non-action.

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EU Carbon Border Adjustment Mechanism (CBAM) +

EU CARBON BORDER ADJUSTMENT MECHANISM (CBAM) Regulation (EU) 2023/956

Adopted
Apr. 18, 2023

Published
Oct. 8, 2025

Transition Phase Began
Oct. 2023

Definitive Implementation Phase
Jan. 1, 2026

Published in EU Official Journal: https://eur-lex.europa.eu/eli/reg/2025/2083/oj/eng

Penalties

Penalties are designed to ensure compliance with the CBAM regulations and to prevent carbon emissions being shifted to low-regulation markets.

Penalty for unreported emissions during Transitional Phase (ending 2025): Between €10 and €50 per tonne of emissions that are not reported accurately.
Penalty for unreported emissions during Definitive Implementation Phase (starting Jan. 1, 2026): Significant fines linked to the EU ETS price (€100+/tonne) for failing to surrender certificates, with potential for persistent non-compliers to be barred from the EU market, alongside domestic penalties set by member states.
Penalty for missing, incorrect, or incomplete CBAM reports: The National Competent Authority (NCA) may initiate a correction procedure, which allows reporting declarants to rectify potential errors.
Penalty for failing to surrender sufficient CBAM certificates: Declarants will be liable to pay a penalty identical to the penalty under the EU ETS applicable in the year of importation of the goods.

Switzerland's Regulatory Alignment

INSIGHTS

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Swiss CO₂ Act +

SWISS CO₂ ACT

Adopted revised CO₂ Act
Mar. 15, 2024

Published
Mar. 15, 2024

Enforced revised CO₂ Act
Jan. 1, 2025

The Swiss CO₂ Act is the central legal framework for reducing greenhouse gas emissions in Switzerland. It shapes climate policy to meet climate targets, aiming for a 50% reduction of greenhouse gas emissions by 2030 (compared to 1990 levels). The law also includes an amendment to the Unfair Competition Act, banning unsubstantiated claims about the climate impact of products or services.

The CO₂ Act uses financial incentives like a CO2 levy on heating fuels, invests in climate-friendly technologies, and sets emission standards for vehicles, supporting the national goal of net-zero emissions by 2050.

CO₂ levy exemption is for:

Companies in energy-intensive sectors. Strict conditions includes a Reduction Obligation Agreement with the Federal Office for the Environment (FOEN), committing to specific emission reduction targets and submitting a decarbonisation plan (Net Zero Plan) every three years with annual report on emissions audited by an independent Assessment Body.
Operators of large, greenhouse-gas-intensive plants that participate in the Emissions Trading System (ETS)
Operators of fossil fuelled Combined Heat and Power (CHP) Plants if used to generate electricity.

For aviation flight tickets, emissions in CO₂ equivalents must be noted on flight tickets. Sustainable Aviation Fuel (SAF) requires a binding blending mandate for sustainable aviation fuels of 2% by 2026, and 6% by 2030).

Swiss publication platform:: https://www.fedlex.admin.ch/eli/cc/2012/855/en

Penalties

All penalties collected for violations of the blending requirement or from the auctioning of aircraft emission allowances are earmarked for the Aviation and Climate funding program, which supports the adoption and production of SAF.

The incentive tax on fossil fuels (heating oil, natural gas) remains set at CHF 120 per tonne and this equates to roughly 30 centimes per litre of heating oil. Two-thirds of this revenue is redistributed to the population and businesses, while one-third goes into a national climate fund for building renovations and renewable energy.
Small and LCVs: 2025 - 2029 targets: 93.6 g CO₂/km for passenger cars. and 153.9 g CO₂/km for LCVs. Penalty range for exceeding the target: CHF 95 to CHF 152 per gram of CO₂/km.
Heavy-Duty Vehicle (HDV): 2025 - 2029 targets: 93.6 g CO₂/kg. Penalty range for exceeding the targe: fCHF 4,250 to CHF 6,800 per gram/tonne-km (2025–2029) and higher from 2030.
ETS Non-Compliance: Aircraft operators failing to surrender sufficient emission allowances for their flights (within Switzerland and to the EU/UK) must pay a penalty of CHF 125 per tonne of CO₂ equivalent and the operator must still surrender the missing allowances in the following year.
SAF Blending Mandate Shortfall (from Jan 1, 2026): Fuel suppliers who fail to meet the mandatory blending requirements for sustainable aviation fuel (SAF) face a penalty equivalent to twice the price gap between SAF and fossil jet fuel for the shortfall. They are also required to compensate for the missing volume the following year.
Failure to Report/Properly Conduct Inspection: Penalties may be imposed for failing to properly monitor or report emissions, or for obstructing inspection, with fines potentially reaching the amount of any unlawful benefit or calculated as a high fine under administrative criminal law.
Airport Infrastructure Penalty: Airport operators that fail to provide adequate infrastructure for SAF refueling face a fine of CHF 0.50 per departing flight annually.

INSIGHTS

PwC SWITZERLAND: Vote on the new Swiss CO2 Act: what’s next for businesses?

CLIMATE CHANGE LAWS OF THE WORLD: Mar. 15, 2024 – CO₂ ACT

SWI Swissinfo.ch: Mar. 15, 2024 - Parliamentary resolutions on the revised CO2 Act: An overview

DELOITTE: Jul. 9, 2024 - Sustainable carbon credits strategy for the hospitality industry

INTL CARBON ACTION PARTNERSHIP: Jan. 1, 2025 - Swiss ETS reform comes into force

NOW Insight: Impacts to the Hospitality Industry

The Swiss CO₂ Act (and subsequent 2025 Climate and Innovation Act) drives the hospitality industry toward a net-zero target by 2050, heavily impacting operations through increased taxes on fossil fuels (CHF 120 per tonne of CO₂) and stricter building standards. The sector is responsible for significant emissions through heating and cooling and must adopt energy-efficient technologies, reduce food waste, and improve sustainability to avoid higher costs.

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Swiss Federal Act on Climate Protection Targets, Innovation & Strengthening Energy Security +

SWISS FEDERAL ACT ON CLIMATE PROTECTION TARGETS, INNOVATION & STRENGTHENING ENERGY SECURITY

Approved
Jun. 18, 2023

Published
Jun. 18, 2023

Enforced
Jan. 1, 2025

The Federal Act on Climate Protection Targets, Innovation and Strengthening Energy Security (also known as the Climate and Innovation Act) and its implementing ordinance - Climate Protection Ordinance (CPO) enshrines a legally binding goal to reach net-zero greenhouse gas emissions by 2050.

It sets an intermediate target of 64% reduction for 2031 – 2040 and an 89% reduction 2041 – 2050 compared to 1990 levels. Companies are encouraged to create "net-zero roadmaps" to reduce Scope 1, 2 and 3 emissions, with exceptions for the agricultural sector.

Financial support is available for companies implementing innovative, climate-friendly technologies. The government provides CHF 1.2 billion in aid over 6 years for innovative, emission-reducing projects and sector specific funding is available for replacing fossil-fuel heating systems and supports large-scale solar installations.

Swiss publication platform: https://www.admin.ch/gov/en/start/documentation/votes/20230618/climate-and-innovation-act.html

Penalties

While the Climate and Innovation Act focuses on incentives, but related legislation passed alongside it, particularly the revised Unfair Competition Act (UCA), introduces legal consequences:

Anti-Greenwashing - Article 3(1)(x) of the UCA requires companies to substantiate climate-related claims in reports, advertisements, or roadmaps with independent, verifiable evidence. Failure to do so can lead to civil and criminal consequences.
The financial regulator FINMA, under the revised CO₂ Act, must assess climate-related financial risks for supervised institutions.
Large public interest companies required to publish climate disclosures (including transition plans) must ensure accuracy or risk penalties under corporate reporting obligations.

INSIGHTS

PwC SWITZERLAND: Switzerland commits to climate neutrality by 2050: A call for action

ISOMETRIC: What the Swiss Climate and Innovation Act means for carbon removal

ETHICS & COMPLIANCE SWITZERLAND: Dec. 2, 2024 - New Climate and Innovation Act enters into force on 1 January 2025

NOW Insight: Impacts to the Hospitality Industry

The Climate and Innovation Act (and the previous Swiss CO2 Act) drives the hospitality industry toward a net-zero target by 2050, heavily impacting operations through increased taxes on fossil fuels (CHF 120 per tonne of CO₂) and stricter building standards.

The sector is responsible for significant emissions through heating and cooling and must adopt energy-efficient technologies, reduce food waste, and creating credible "net-zero roadmaps" for businesses to remain competitive and align with Switzerland's broader climate goals.

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EU Industrial Emissions Directive (IED) +

EU INDUSTRIAL EMISSIONS DIRECTIVE (IED) Directive (EU) 2010/75

Adopted
Apr. 12, 2024

Published
Jul. 15, 2024

Enforced
Aug. 4, 2024

Transpose in EU Member States Deadline:
Jul. 1, 2026

Apply in EU Member States:
2030 - 2032

Published in EU Official Journal: https://eur-lex.europa.eu/eli/dir/2010/75/oj/eng

Penalties

Vary by Member State and designed to be effective, proportionate, and dissuasive.

Maximum fines of at least 3% of the operator's annual EU turnover plus Member States are required to establish a system of penalties to include further administrative fines.
Individuals to seek compensation for damages to their health caused by violations of national rules implementing the IED.
Suspension of operations.

Switzerland's Regulatory Alignment

INSIGHTS

NOW Insight: Impacts to Hospitality Industry

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EU Renewable Energy Directive (RED) +

EU RENEWABLE ENERGY DIRECTIVE (RED III) (EU) 2023/2413

Revision Adopted
Mar. 30, 2023

Published
Oct. 31, 2023

Enforced in EU Member States
Nov. 20, 2023

Appliedin EU Member States
May 21, 2025

Published in EU Official Journal: https://eur-lex.europa.eu/eli/dir/2018/2001/oj/eng

Penalties

RED III imposes strict penalties for failing to meet renewable targets by 2030 that will vary by Member State and designed to be effective, proportionate, and dissuasive.

Targetting fuel, €120/GJ will be charge for non-compliance with RFNBO mandates, potential fines of €17,000/t for e-SAF, and legal actions/financial sanctions against member states failing to transpose directives.
For transport fuel suppliers, a penalty of €120 per gigajoule (GJ) is applied to obligated companies failing to meet targets for renewable fuels of non-biological origin (RFNBOs), such as green hydrogen, which rise to 2.5% in 2034 and 8% in 2040.
For compliance and reporting, companies must maintain rigorous, verified documentation for the entire chain of custody for biofuels. Stricter, more granular guarantees of origin (GO) with 1 MWh standards are now required to prevent fraud.

Switzerland's Regulatory Alignment

INSIGHTS

NOW Insight: Impacts to Hospitality Industry

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Swiss Federal Act on a Secure Supply of Electricity from Renewable Energy Sources (“Mantelerlass”) +

SWISS FEDERAL ACT ON A SECURE ELECTRICITY SUPPLY FROM RENEWABLE ENERGY SOURCES

Passed by Parliament
Autumn 2023

Approved by Voters & Published
Jun. 9, 2024

Enforced 1st Package:
Jan. 1, 2025

Enforced 2nd Package:
Jan. 1, 2026

The Federal Act on a Secure Electricity Supply from Renewable Energy Sources, commonly known as “Mantelerlass”, is a Swiss legislation acting as an umbrella decree, amending several existing laws – the Energy Act, Electricity Supply Act, Spatial Planning Act, and Forestry Act - to accelerate the expansion of domestic renewable energy production and to ensure a secure, sustainable, and independent electricity.

It introduces a solar obligation for buildings, facilitates the construction of large solar/wind projects, and supports the creation of local electricity in communities.

Swiss publication platform: https://www.fedlex.admin.ch/eli/oc/2024/679/fr

The Act have five objectives.

To set mandatory, ambitious expansion targets for wind, solar, and hydropower for 2035 and 2050.
To focus on strengthening Switzerland's independent energy supply, especially during winter, to reduce reliance on imports.
To introduce "local electricity communities" (LEG), promote smart metering for consumers, and set mandatory energy efficiency targets for suppliers.
To streamline that approval procedures for 16 specific large-scale hydropower projects and prioritizes wind/solar plants of "national interest".
To introduces a mandatory solar installation requirement for new buildings with a surface area over 300 m².

Penalties

While the Climate and Innovation Act focuses on incentives, but related legislation passed alongside it, particularly the revised Unfair Competition Act (UCA), introduces legal consequences:

Anti-Greenwashing - Article 3(1)(x) of the UCA requires companies to substantiate climate-related claims in reports, advertisements, or roadmaps with independent, verifiable evidence. Failure to do so can lead to civil and criminal consequences.
The financial regulator FINMA, under the revised CO₂ Act, must assess climate-related financial risks for supervised institutions.
Large public interest companies required to publish climate disclosures (including transition plans) must ensure accuracy or risk penalties under corporate reporting obligations.

INSIGHTS

NOW Insight: Impacts to the Hospitality Industry

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Swiss Environmental Protection Act (EPA) +

Swiss Federal Act on the Protection of the Environmental (EPA) SR 814.01

Adopted
Oct. 7, 1983

Published
Oct. 7, 1983

Enforced
1985

Amended to strengthen circular economy
Apr. 1, 2025

The Swiss Federal Act on the Protection of the Environment (Environmental Protection Act - EPA) focuses on preventing harmful impacts, managing waste, and implementing the "polluter pays" principle. It applies to air, noise, soil, and waste. 2025 amendment includes a federal ban on littering, stricter waste recovery, and enhanced regulations for sustainable, circular economy practices.

The law requires the Federal Council to assess the state of the environment every four years and enforcement conducted primarily by cantons under federal supervision.

Published in EU Official Journal: https://www.fedlex.admin.ch/eli/cc/1984/1122_1122_1122/en

Penalties

While the Climate and Innovation Act focuses on incentives, but related legislation passed alongside it, particularly the revised Unfair Competition Act (UCA), introduces legal consequences:

Criminal Liability: Deliberate or negligent infringement of regulations can result in custodial sentences of up to three years or monetary penalties.
Specific Infringements: Emissions: Failing to meet air quality standards (OAPC) or ignoring remediation orders can lead to fines up to CHF 20,000. Waste/Special Waste: Improper handling, unauthorized transport, or improper disposal of special waste (e.g., chemicals, certain cleaning agents) can lead to severe penalties.
Polluter Pays Principle: Costs for cleaning up environmental damage caused by the business are borne by the operator.

INSIGHTS

HARTING: Mar. 19, 2025 - Things are moving forward in environmental law!

Lenz & Staehelin: Switzerland ENVIRONMENT

NOW Insight: Impacts to the Hospitality Industry

EPA significantly impacts the hospitality industry. Hotels and restaurants must comply with strict waste management regulations, including the "Avoid, Recover, Dispose" principle. Amendments to the EPA (effective 2024) focus on new circular economy rules on resource efficiency and reducing environmental impacts of buildings, affecting construction and renovations. Stationary installations (e.g., heating systems, laundry facilities) must meet strict air quality standards and emission limits; otherwise, they face mandatory retrofitting or shutdown.

Operators must maintain proper documentation and, in some cases, submit environmental impact reports for major renovations to ensure readiness when authorities conduct spot checks.

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EU Sustainable Use of Pesticide Directive (SUPD) +

EU SUSTAINABLE USE OF PESTICIDE DIRECTIVE (SUPD or SUD) (2009/128/EC)

Adopted & Published
Oct. 21, 2009

Enforced
Nov. 25, 2009

Transposed Deadline
Nov. 26, 2011

Apply EU Member States:
2011/201

Mandatory IPM implementation:
2014

Harmonised Risk Indicators Update:
2019/2021

Published in EU Official Journal:: https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:309:0071:0086:en:PDF

Penalties

Switzerland's Regulatory Alignment

INSIGHTS

NOW Insight: Impact to Hospitality Industry

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Swiss Plant Protection Products Ordinance +

Swiss Plant Protection Products Ordinance (PSMV) (PPPO, SR 916.161)

Revision Approved
Aug. 20, 2025

Enforced
Dec. 1, 2025

Transposed Deadline
Nov. 26, 2011

Apply EU Member States:
2011/2012

Mandatory IPM implementation:
2014

Harmonised Risk Indicators Update:
2019/2021

The Swiss Plant Protection Products Ordinance governs the authorization, sale, and use of plant protection products (PPPs) in Switzerland to ensure safety for humans, animals, and the environment. It requires comprehensive evaluation of active substances and products before market placement, heavily emphasizing environmental protection and pollinator safety.

Certain highly toxic pesticides are banned or restricted to ensure they cannot be exported from Switzerland. Specialized training and licenses are required for the commercial application of pesticides.

Switzerland maintains a close alignment with the EU Sustainable Use of Pesticide Directive to simplify approvals while maintaining Swiss sovereignty on safety standards and the precautionary principle-

Published in Swiss Publication Platform: https://www.fedlex.admin.ch/eli/cc/2025/565/de

Penalties

Penalties can be severe, involving heavy fines, criminal charges, and product confiscation.

Financial Fines: Violations regarding the illegal use or distribution of substances can lead to significant penalties. In similar agricultural violation cases (e.g., in prohibited zones), fines can exceed CHF 3,500, often combined with legal costs.
Confiscation: Unauthorized plant protection products (PPPs) can be seized by authorities.
Border Detainment: Customs offices check for compliance with the Ordinance and are authorized to detain goods at the border, calling in enforcement authorities for illegal imports.
Criminal Charges: In serious cases, such as illicit trade or improper use, criminal charges can be brought, with potential penalties corresponding to the severity of the environmental or health damage caused.
The Federal Office for Agriculture (FOAG) and cantonal authorities enforce the regulations, which can include the revocation of permits to use or sell products.

INSIGHTS

Public Eye: Sept. 23, 2025 - Sharp rise in EU export trade in banned pesticides despite European Commission promises

SWI Swiss Info: Dec. 2025 - New Swiss food regulations for 2026: GMOs, contaminants, pesticides and mushrooms

UFAG Laboratorien: Pesticides

NOW Insight: Impacts to the Hospitality Industry

PSMV impacts the hospitality companies with large outdoor areas and golf courses which will have to adapt to higher operational costs and altered maintenance strategies. Better training for personnel handling pest control is important to maintain low-risk, or biological pest control methods, and safe storage and application of pesticides within the facility.

The approved list of synthetic pesticide products is shrinking, forcing a transition towards biological, mechanical, and more sustainable turf management techniques. Golf Courses face tighter restrictions on fungicides, with many aiming to reduce applications by more than half. Replacing synthetic treatments requires more intensive, often manual, maintenance to manage pests and weeds, leading to increased labour and operational expenses.

With the broader push for credible sustainability certifications, and sustainable procurement in food sourcing and landscaping, companies will have to scrutinise their food supply chains and engage in more sustainable, traceable, and eco-friendly purchasing.

PSMV will encourage hospitality companies to demand food products with lower pesticide residues, which sets supplier and food sourcing standards and drives higher demand for organic or IPM-certified ingredients.

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EU Water Framework Directive +

EU WATER FRAMEWORK DIRECTIVE (WFD) Directive 2000/60/EC

Adopted
Oct. 2000

Published
Sept 26, 2025

Enforced
Dec 22, 2000

Transposed in EU Member States
Jun. 17, 2027

Applied in EU Member States
Apr. 2028

Published in EU Official Journal: https://eur-lex.europa.eu/eli/dir/2000/60/oj/eng

Penalties

Vary by Member State and designed to be effective, proportionate, and dissuasive.

The European Commission monitors compliance and can refer Member States have been referred to the Court of Justice of the European Union for failing to meet standards or update plans.
Criminal liability for severe environmental damage to water quality caused by gross negligence and can lead to prosecutions.

Switzerland's Regulatory Alignment

INSIGHTS

WWF: The EU Water Framework Directive

OECD: Implementing Water Economics in the EU Water Framework Directive

NOW Insight: Impacts to Hospitality Industry

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Swiss Water Protection Act +

SWISS FEDERAL ACT ON THE PROTECTION OF WATERS WPA; SR 814.20

Adopted
Jan. 24, 1991

Published
Jan. 24, 1991

Enforced
Nov. 1, 1992

Updated 2021
for pesticide risk

The Swiss Federal Acct on the Protection of Waters (Water Protection Act - WPA) and its corresponding Water Protection Ordinance (WPO) aims to protect surface and underground waters from harmful effects, and ensures the protection of waters, specifically focusing on drinking water supply, and the preservation of natural habitats.

Swiss publication platform: https://www.fedlex.admin.ch/eli/cc/1992/1860_1860_1860/en

Penalties

Penalties are based on “polluter pays” principle - those responsible for water damage must bear the costs of restoration.

The Swiss Penal Code imposes a custodial sentence of up to five years or a fine on anyone who wilfully contaminates drinking water (people or animals).
If the contamination is caused negligently, the penalty is a custodial sentence of up to three years or a fine.
Wilful failure to comply with emission limitations or remediation orders can result in a fine of up to CHF 20,000
In addition to criminal penalties, authorities may order, restrict, or demand remediation for activities harming water

INSIGHTS

SCIENCE INDUSTRIES OF SWITZERLAND: Nov. 6, 2025 - Water Protection in Switzerland

ROBECCO: Mar. 22, 2022 Switzerland must take care of its groundwater

MME: May 6, 2020 - Climate Law - Revision of the Water Protection Ordinance

NOW Insight: Impacts to the Hospitality Industry

WPA and WPO place strict obligations on the Swiss hospitality industry (hotels, restaurants, campsites) to protect water resources, manage wastewater, and minimize environmental impacts.

Companies have to adopt best practices, including implementing water-saving technologies in showers, toilets, and laundry facilities, and reducing the input of chemical pollutants, directly affecting the types of cleaning agents and detergents used in hotel cleaning and laundry services.

Companies are subject to strict national and cantonal requirements, including discharge permits and specific limit values for pollutants. Stricter thresholds for pesticides and, recently, medicinal substances, are in place, forcing operators to ensure that their wastewater (e.g., from spa facilities or food production) does not violate these standards.

With the tightening of rules, many sectors, including those with substantial water use, are required to adopt advanced treatment or separation techniques, such as collecting and treating highly concentrated waste flows (e.g., grease traps in kitchens) rather than just diluting them. Companies face increased costs for compliance, including investing in, maintaining, or upgrading water treatment systems to meet regulatory standards.

Hotels or businesses operating within, or near, groundwater protection zones (often located in tourist-frequented, sensitive natural areas) face even more stringent rules regarding the use of substances that could threaten water quality.

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EU Waste Framework Directive +

EU WASTE FRAMEWORK DIRECTIVE (WFD) Directive (EU) 2008/98/EC

Adopted
Sept. 9, 2025

Published
Sept 26, 2025

Enforced
Oct .16, 2025

Transposed in EU Member States
Jun. 17, 2027

Applied in EU Member States
Apr .2028

Published in EU Official Journal: https://eur-lex.europa.eu/eli/dir/2025/1892/oj/eng

Penalties

Vary by Member State and designed to be effective, proportionate, and dissuasive.

Penalties are high for improper waste separation, hazardous waste mismanagement and EPR non-compliance for when producers fail to register or pay fees for waste management.
Fines can be severe, such as in the Czech Republic, where failure to comply with food donation obligations can result in fines up to €400,000 (10 million CZK).
Legal action & criminal charges are severe for repeated, or negligent breaches, particularly concerning illegal dumping of hazardous waste which can lead to criminal prosecution.

Switzerland's Regulatory Alignment

INSIGHTS

NOW Insight: Impacts to Hospitality Industry

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EU Batteries Regulation +

EU BATTERIES REGULATION Regulation (EU) 2023/1542

Adopted
Jun. 14, 2023

Published
Jun. 28, 2023

Enforced
Aug 17, 2023

Applied in EU Member States:
General rules – Feb. 18, 2024
Waste Management – Aug. 2025
Digital Battery Passports – Feb. 2027

Published in EU Official Journal: https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng

Penalties

Vary by Member State and designed to be effective, proportionate, and dissuasive.

Significant fines, potentially up to €100,000 per breach or even a percentage of annual revenue
Marketing and sales bans for products failing to meet requirements, such as lacking valid registration or compliance documentation

Switzerland's Regulatory Alignment

INSIGHTS

NOW Insight: Impacts for Hospitality Industry

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EU Packaging & Packaging Waste Regulation (PPWR) +

EU PACKAGING AND PACKAGING WASTE REGULATION (PPWR) (EU) 2025/40

Adopted
Dec. 13, 2025

Published
Jan. 22, 2025

Enforced
Feb. 11, 2025

Applied in EU Member States:
Aug. 12, 2026

Phases of specific targets for
2030, 2035, 2040

NOTE: Swiss companies operating within the EU must comply with PPWR.

Published in EU Official Journal: https://eur-lex.europa.eu/eli/reg/2025/40/oj/eng

Penalties

Vary by Member State and designed to be effective, proportionate, and dissuasive.

Producers must register in each Member State and contribute to EPR (Extended Producer Responsibility) schemes, with fees modulated based on the packaging's sustainability (eco-modulation).
Manufacturers must prepare technical documentation and a declaration of conformity, which must be kept for 5–10 years.

Switzerland's Regulatory Alignment

INSIGHTS

NOW Insight: Impacts to Hospitality Industry

Q1 2026 Update - UK Sustainability Framework & Insights +

Available soon.

2026 EU Crackdown On Green Claims

The Empowering Consumers for the Green Transition Directive (ECGTD), also known as EmpCo, will be enforced by March 27, 2026, the deadline date for EU Member States to transpose the directive into national law, with rules and penalties to apply within 6 months.

EmpCo will affect all companies in the EU and abroad that make any sustainability claims and target the EU consumer. It's already law in Italy since November 2025!

To better protect EU consumers, EmpCo is focused on

prohibiting misleading claims such as vague or unproven sustainability promises,
providing better information about sustainability, lifespan, repairs and warranties,
and helping EU consumers make informed, sustainable choices.

WHAT YOU NEED TO DO

MAKE SURE GREEN CLAIMS ARE SUBSTANTIATED & VERIFIED

by an independent, accredited Certification Body and accessible in target markets. You have a choice! Talk about credibly verified sustainability ... or HUSH and stop talking!

KNOW THE SERIOUS CONSEQUENCES!

Fines and penalties are high and greenwash accusations will damage reputations.

March 27 is looming! ARE YOU READY? NOW can help.

What We Do At NOW

NOW provides knowledge, expertise and support sustainability journeys focused on A.C.T.I.0.N. to help manage risks,
to save money, to ensure credibility, to meet regulatory requirements and to enhance brand reputation.

What We Offer

If you become a NOW Member, we can provide these 10 solutions to support your team, to bring credibility and integrity to the sustainability process, to withstand regulatory scrutiny, to communicate sustainability simply with transparency to engage stakeholders and to help achieve Net Zero goals.

NOW Advisors Hub - Services

Build knowledge - Green Partner Academy
Internal Audit & Baseline Review
Train Green Team or Coordinator
Prepare Audit Reports
Audit Preparation / Attendance
External Sustainability Officer
Hotel Group Certification

VIEW

NOW Sustainability Reporting Tool

A savvy technology to simplify comprehensive and evidenced sustainability reporting for accessible, easy to understand, engaging and transparent communication with all stakeholders. Extra added link for Direct Booking.

VIEW

Climate Action with Benefits

Providing access to certified high-integrity projects with high-quality carbon credits to achieve New Zero goals. Plus 5-10% rebate on purchase (max €10 K)

VIEW

Join NOW

As an industry, we need to embrace transformative change. Greenwashing and inaction are no longer acceptable. NOW asks the right questions and provides insights and advice on what best practice actually looks like.EarthCheck
Stewart Moore, Founder

The European Hotel Managers Association is proud to announce our partnership with NOW Transforming Hospitality. This collaboration represents a shared commitment to driving sustainability, innovation, and excellence in the hospitality industry. By working together, we aim to empower hotels to embrace transformative practices that not only elevate guest experiences but also prioritize environmental and social responsibility. This is the future of hospitality, and we are excited to lead the way.European Hotel Managers Association (EHMA)
Panos Almyrantis, President EHMA

It was clear that NOW would take us on a focused and thorough sustainability journey and we specially like the idea of striving towards accreditation for our actions. We are aiming high in all that we do and this includes our goal to achieve Net Negative Emissions. NOW is most definitely proving to be a Force for Good.Positive Hospitality
Sue Williams, Founder (exGM, Whatley Manor)

NOW is clearly ahead of the game - setting best practice, offering certification tools, and creating signalling effects. We think that, as the climate emergency intensifies, such organisations will put into motion a snowball cascade effect. Expansion will be exponential, not linear. Latecomers and doubters beware.Monthly Barometer
Thierry Malleret, Managing Partner

Sustainability is at the heart of Soneva. Our core purpose is engaging an imaginative Slow Life and we have incorporated sustainability into our fabric from the very beginning.

We are pleased to team up with NOW to drive sustainability throughout the industry.Soneva
Sonu Shivdasani, Founder

Hotel Partners

Register interest to join the NOW Force for Good.

Why the Hospitality Industry Needs NOW

Be In Good Standing

Q1 2026 Update - EU Sustainability Framework & Insights +

Communications, Reporting & Disclosure

EU Corporate Sustainability Reporting Directive (CSRD) +

EU CORPORATE SUSTAINABILITY REPORTING DIRECTIVE (CSRD) Directive (EU) 2022/246

Penalties

The Omnibus Package

Switzerland's Regulatory Alignment

Penalties

INSIGHTS

NOW Insight: Impacts to the Hospitality Industry

EU Empowering Consumers for the Green Transition Directive (ECGTD) +

EU EMPOWERING CONSUMERS FOR THE GREEN TRANSITION DIRECTIVE (ECGTD) Directive (EU) 2024/825

Penalties

Switzerland's Regulatory Alignment

Penalties

INSIGHTS

NOW Insight: Impacts to the Hospitality Industry

EU Taxonomy Regulation (EUTR) +

EU TAXONOMY REGULATION (EUTR) Regulation (EU) 2020/852

Penalties

INSIGHTS

NOW Insight: Impacts to the Hospitality Industry

EU Sustainable Finance Disclosure Regulation (SFDR) +

EU SUSTAINABLE FINANCE DISCLOSURE REGULATION (SFDR) Regulation (EU) 2019/2088

Penalties

INSIGHTS

NOW Insight: Impacts to the Hospitality Industry

EU Whistleblowers Directive +

EU WHISTLEBLOWING DIRECTIVE Directive (EU) 2019/1937

Whistleblowing Platforms

Penalties

INSIGHTS

NOW Insight - Impacts to the Hospitality Industry

Supply Chain & Products

EU Corporate Sustainability Due Diligence Directive (CSDDD) +

EU CORPORATE SUSTAINABILITY DUE DILIGENCE DIRECTIVE (CSDDD) Directive 2024/1760

Fines and Penalties

Switzerland's Regulatory Alignment

Penalties

INSIGHTS

NOW Insight: Impacts to the Hospitality Industry

EU Ecodesign for Sustainable Products Regulation (ESPR) +

EU ECODESIGN FOR SUSTAINABLE PRODUCTS REGULATION (ESPR) Regulation (EU) 2024/1781

Penalties

Switzerland's Regulatory Alignment

Penalties

INSIGHTS

NOW Insight - Impacts to the Hospitality Industry

EU Deforestation Regulation (EUDR) +

EU DEFORESTATION REGULATION (EUDR) Regulation (EU) 2023/1115

Penalties

Switzerland's Regulatory Alignment

INSIGHTS

NOW Insight - Impacts to the Hospitality Industry

Climate & Environment

European Climate Law +

EUROPEAN CLIMATE LAW Regulations (EU) 2021/1999

Penalties

Switzerland's Regulatory Alignment

INSIGHTS

NOW Insight: Impacts to Hosptiality Industry

EU Carbon Border Adjustment Mechanism (CBAM) +

EU CARBON BORDER ADJUSTMENT MECHANISM (CBAM) Regulation (EU) 2023/956

Penalties

Switzerland's Regulatory Alignment

INSIGHTS

EU Industrial Emissions Directive (IED) +

EU INDUSTRIAL EMISSIONS DIRECTIVE (IED) Directive (EU) 2010/75

Penalties

Switzerland's Regulatory Alignment

INSIGHTS

NOW Insight: Impacts to Hospitality Industry

EU Batteries Regulation +

EU BATTERIES REGULATION Regulation (EU) 2023/1542

Penalties

Switzerland's Regulatory Alignment

Register interest to join the
NOW Force for Good.

EU
Aligned

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EU Corporate Sustainability Reporting Directive (CSRD) +

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EU Empowering Consumers for the Green Transition Directive (ECGTD) +

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EU Whistleblowers Directive +

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Geneva Whistleblowing Law +

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EU Corporate Sustainability Due Diligence Directive (CSDDD) +