The Empowering Consumers for the Green Transition Directive (ECGTD – EU 2024/825) is enforced today – the 27th of March 2026 – the deadline date for EU Member States to enact its provisions into national law. 

Also known as EmpCo, it aims to make sure consumers receive relevant and accurate information about the sustainability performance, characteristics and certifications of the products and services they purchase to ensure more sustainable purchases, as well as foster trust and harmonization across the European Single Market.

While there are many EU regulations that focus on the content of products and company practices, EmpCo completes the process by stipulating how companies communicate their environmental and social performance to consumers through marketing communications, labels and certificates. 

EmpCo makes sustainability communications a matter of legal and operational responsibility for companies by imposing clearer rules and stricter substantiation and verification requirements, with serious penalties for non-compliance.

IN A NUTSHELL – EU DIRECTIVES ON “GREEN CLAIMS”

The European Commission designed two directives on “green claims” to stop greenwashing.

1. The Green Claims Directive is in limbo following industry concerns regarding the administrative burden (especially on SMEs).

2. The Empowering Consumers for the Green Transition Directive, also known as EmpCo, was adopted into law on the 28th of February 2024 and published in the EU Official Journal: https://eur-lex.europa.eu/eli/dir/2024/825/oj/eng.

– EmpCo is enforced the 27th of March 2026, the deadline date for EU Member States to transpose the directive into national law and set “effective, proportionate, and dissuasive” penalties for violations. Application of rules and penalties will start on September 27, 2026.

– EmpCo’s impact is global. Regardless of size or location, EmpCo rules apply to any business (in the EU and abroad) that communicate sustainability-related claims and target the EU consumers.

– EmpCo applies to all voluntary, business-to-consumer (B2C) sustainability-related communications and certifications. Penalties for violations will be “effective, proportionate, and dissuasive”.

– EmpCo enhances the EU Consumer Protection Directives (2005/29/EC and 2011/83/EU) by:

+ Updating the list of prohibited misleading commercial practices and certain environmental claims into Annex I of the Unfair Commercial Practices Directives. 
+ Establishing requirements for substantiating green claims.
+Requiring traders to provide consumers with detailed information regarding the method of comparison, the products being compared, and the suppliers of those products in comparative advertising.
+ Establishing minimum standards for sustainability labels by providing a legal definition of what constitutes a ‘certification scheme’ under EU law.

EmpCo amends the Unfair Commercial Practices Directive to ban vague, misleading, and unverified green claims. It stipulates maximum fines of up to 4% of a company’s turnover in the Member State concerned, or 2 million EUR, in case of non-compliance. Additionally, greenwashing scandals can negatively impact a company’s value by eroding consumer confidence and causing stock market value destruction.

WHAT HOSPITALITY COMPANIES MUST DO?

In a regulated market, sustainability is no longer flexible, and companies can no longer cherry-pick their impacts and self report or mislead. Greenwashing has consequences. Hospitality companies can expect compliance and reputational burdens for unsubstantiated and unverified communication and storytelling of their environmental and social performance.

To avoid accusations of greenwashing, hospitality companies should:

1. Audit to identify and categorise all sustainability-related communications based on EmpCo bans and restrictions.  

Review every touchpoint – marketing materials, corporate branding, sustainability labels and future claims – and conduct a Gap and Risk Analysis.

2. Assess your current certifications

Sustainability labels are under scrutiny. For each certification or label you display, verify:

– Are the scheme requirements publicly available?

– Is compliance monitored by an independent third party according to ISO 17065?

– Is the scheme open to all operators under fair terms?

– Is the scheme owner legally separate from the verification body that conduct the audit and provide the certification?

If you cannot confirm these points, that label is at risk. Data driven sustainability scheme audit by an independent accredited Certification Body is mandatory.

3. Identify compliant alternatives.

Seek certifications that meet all EmpCo requirements: independent verification, legal separation, public criteria, ISO 17065-compliant monitoring, and stakeholder-consulted standards.

4. Remove or remediate non-compliant claims.

The European Commission confirms that hotels may use practical solutions for existing materials: stickers to cover non-compliant claims, supplementary information at point of sale, or updated digital content.

5. Rebuild your claims based on evidence. 

Any environmental claim must now be specific and substantiated. Instead of “eco-friendly hotel,” specify: “100% renewable electricity” or “zero single-use plastics in guest rooms”— with evidence readily available. 

WHAT MAKES A CERTIFICATION SCHEME COMPLIANT?

The European Commission’s Q&A (November 2025) sets clear criteria.

A certification scheme must have:

– Independent third-party verification — self-certification is not acceptable.

– Publicly available requirements — if you can’t find the scheme’s criteria online, it’s a red flag.

– Competent, independent compliance monitoring — in line with ISO 17065 or equivalent standards.

– Legal separation between scheme owner and verifier — even if international standards might allow otherwise, EmpCo requires two different legal entities.

– Transparent, fair, and non-discriminatory access — open to all traders willing to comply

– Stakeholder consultation in setting requirements.

If a hotel’s current certification doesn’t meet these criteria, the associated label should be removed from all commercial communications.

CAUTION TO HOSPITALITY COMPANIES: Your company will risk accusations of greenwashing with severe penalties for using non-compliance sustainability certification and not the non-compliant certification scheme owners.

A certification scheme must have a Conformity Assessment Body (CAB) to independently manage the audit process and provide the certification, such as Control Union Certifications BV, which is also a leading certification body with a global quality management system based on standards ISO/IEC 17020, ISO/IEC 17065 and ISO/IEC 17021 and constantly reviewed by numerous national and international accreditation bodies.

Control Union Lead Auditor, Certifier & Tourism/Hospitality Certifications Coordinator Peter Henkes explained, “Because of the Empowering Consumers Directive, hotel companies must be clear about their sustainability claims. Any environmental claims verified and certified by an independent, accredited certification body, such as Control Union Certifications, ensure that these claims are true and comparable. It reinforces guest trust, prevents greenwashing, and ensures that hotels comply with regulatory requirements for responsible, transparent hospitality practices.”

VIEW Scheme vs Certification vs Accreditation

SUSTAINABILITY REPORTING THAT ENGAGES STAKEHOLDERS

For hospitality companies worldwide targeting the EU consumer, sustainability-related communications must not only align with EmpCo’s requirement to provide transparent, specific, substantiated, verified and accessible information, it must also engage stakeholders (guest and client, owner and investor, employee and management, supplier, travel operator, media, auditor, etc.) to gain their support.  

The NOW Sustainability Reporting Tool is an engaging technology designed 

– To help hospitality companies align with EmpCo requirements.
– To make sustainability-related data and evidence easier to explain and understand.
– To use clear metrics and transform data into visuals and compelling stories.
– To showcase certifications to validate efforts and communicate with credibility.
– To engage staff to participate, which can lead to higher satisfaction and staff retention.
– To engage guests and make data accessible in every touchpoint of the hotel experience.
– To help drive revenue with highlighted direct booking links.
– To encourage stakeholder response for 2-way communications.
– To help build stakeholder trust and support.

For stakeholders – Hotel Management and Staff, it provides:

– Accountable, transparent & compliant information source for the Hotel Team.
– A training tool for Human Resource & Sustainability Manager / Coordinator
– A Sustainability Info Kit for Marketing and PR and a Sales tool for Sales Team.
– Sustainability information to link to QR code for F&B Menu, Spa Menu, event boards & digital monitors.

For stakeholders – Guests/Clients, Suppliers, Travel Operators, Media & Auditors, it provides accountable, transparent & compliant information around sustainability that is easy to understand.

View how European hotel leaders in sustainability use the NOW Sustainability Reporting Tool:

View WHATLEY MANOR, UK

View THE ALPINA GSTAAD, Switzerland

View GRAND HOTEL HUIS TER DUIN, Netherlands

THE BOTTOM LINE 

EmpCo is not about adding bureaucracy. It is about separating credible sustainability performance from marketing noise. Hotels that have invested in accountable sustainability will benefit — their credentials will stand out once the non-compliant labels disappear from the market. Hotels relying on weak certifications or vague claims face a choice: upgrade to compliant schemes, substantiate every claim with evidence, or remove the labels entirely. This is not guidance. This is law—with no transition period.

Andres Fellenberg Van der Molen, Director of Green Partner Audits & Consultancy B.V and Senior Lead Auditor for Hotel & Tourism Certifications, observed, “I have seen sustainability in the hospitality industry evolve from good intentions to strategic necessity, and now to something far more critical: accountability. What concerns me is not the EmpCo Directive itself, but how unprepared much of the industry still is to support what it has been claiming on sustainability for years. 

Andres explained, “My view is simple … a hotel should only communicate when they can evidence their sustainability story through data, systems, and operational discipline. This moment is an opportunity to reset, to move away from superficial messaging and towards real, measurable performance that can actually improves the business.”

For credibility, managing risks and regulatory protection, investing in a rigorous Internal Audit and Baseline Review by a qualified Sustainability Specialist is a vital place to start to “walk the line”.

– To know your complete baseline.

– To truly understand the quality of your sustainability knowledge, practices, training, measurements, certification, audits, Environmental Management System and regulation compliance.

– To save money by identify cost-saving opportunities across energy, water, waste and compliance.

– To determine the right strategies and sustainability framework design and tailor a Sustainability Action Plan with quantified benefits.

Sue Williams, founder of Positive Hospitality Ltd. in the UK, observed, “In the UK, although many hotels have embarked on their sustainability journey, it remains clear that when relevant legislation is discussed, the majority of Hoteliers still believe that all we do in this space remains voluntary and there is no urgency to act.”  

Sue emphasised, “This is now incorrect thinking with the enforcement of EmpCo.  If UK hotels communicate any sustainability-related claims targeted to an EU consumer, they must be substantiated, verified and accessible. It would be wise to also extend this to consumers in the UK and outside Europe. Only then can hotels protect their business and reputations from the risk of greenwashing and falling fowl of legislation and their penalties. There is a rapidly growing level of risk in this space for businesses and the time to build rigour is NOW.”

VIEW Be In Good Standing – European Sustainability Framework & Insights