A separate, stalled EU law caused genuine confusion in the industry. This is the one that’s still coming, on schedule, with real teeth.
If you’ve heard that the EU’s crackdown on hotel greenwashing got pushed back, you’ve heard about the wrong law. Two EU directives were designed to arrive together and reshape how hotels describe their environmental performance. One of them, the Green Claims Directive, which would have required accredited third-party verification before any environmental claim could even be published, stalled in Brussels last year and remains genuinely uncertain. The other, the Empowering Consumers for the Green Transition Directive, EmpCo for short, was never affected by that delay. It becomes fully enforceable across the EU on 27 September, roughly three weeks from now, and it’s the one that actually governs a hotel’s website, its OTA listing, and its marketing emails.
What EmpCo Actually Does
EmpCo bans vague, unsubstantiated claims like “eco-friendly,” “green” or “sustainable” unless they’re backed by evidence that’s clear, objective, publicly available and verifiable. It bans “carbon neutral” claims based solely on offsetting outright, not softened, banned. And it applies regardless of where the business is based. A resort in Bali or a hotel in Phuket marketing to European travellers has to comply exactly as a Paris hotel would, location is irrelevant, only who the marketing reaches matters.
The clearest sign this has real consequences already exists. In March 2024, the District Court of Amsterdam delivered what’s been described as the first greenwashing judgment against an airline, ruling 15 of 19 statements in KLM’s advertising misleading, specifically its use of “sustainable” and its CO2ZERO offsetting products, the same category of claim EmpCo now bans outright across every sector. That ruling predates EmpCo’s own enforcement date, which tells you regulators and courts in this part of the world were already willing to act on exactly this kind of claim before the law even required them to.
KLM’s 2024 court defeat over its environmental claims is the clearest sign EmpCo’s enforcement isn’t theoretical.
Enforcement isn’t automatic vetting. Nobody is checking every hotel website on 27 September and issuing fines by lunchtime. It works through complaints, market monitoring, and regulatory investigation, national systems, and penalties vary by country. But that’s not the same as low risk. Once a complaint lands or a claim gets flagged, a hotel that can’t back up “sustainable” with real evidence is exposed to fines of up to 4% of annual revenue and can have profits from the non-compliant campaign confiscated entirely. There’s no grace period either, material already live on 27 September has to comply from that date, not from whenever it was first published.
For a reader, the practical shift is this: from late September, a “sustainable” or “eco-friendly” claim that survives on a hotel’s own website is one that’s actually had to clear a real bar, not just sound good. That doesn’t mean every claim you’ll see already meets it, enforcement takes time to catch up with marketing copy, but it does mean the claims are now legally risky to make falsely in a way they weren’t three months ago.
How to Check for Yourself, and What to Watch For
One genuinely useful development sits underneath all this. Travalyst, the non-profit coalition behind Booking.com’s Travel Sustainable Badge and backed by Expedia, Google, Tripadvisor and several other major travel platforms, maintains a growing list of sustainability certification schemes it recognises as meeting credible, independently verified standards. It updated that list to 83 schemes on 24 July 2026, deliberately timed and aligned with EmpCo’s own requirements ahead of the September deadline. If a hotel is displaying a badge or certification you don’t recognise, checking whether it appears on Travalyst’s list is a faster, more concrete test than trying to judge the claim’s wording yourself. It won’t catch every legitimate scheme, smaller regional certifications sometimes aren’t listed simply because they haven’t gone through that particular process, but if a badge is entirely absent from any recognised accreditation list anywhere, that’s worth treating as a real amber flag.
Checking whether a certification appears on a recognised accreditation list is a faster test than judging marketing language alone.
We’ve written before about how to spot the softer signs of greenwashing in general, and about which specific labels tend to hold up under scrutiny, that ground doesn’t need repeating here: How to Spot Greenwashing and The Sustainability Labels on Your Hotel Booking, Decoded both go deeper into that. What’s different about EmpCo is that it’s not asking you to be a savvier reader of marketing copy. It’s putting legal weight behind the claims themselves, for the first time, with a specific date attached.
If you’re booking a Southeast Asian property for later this year and its website leans on sustainability in its pitch, it’s worth watching whether vague language starts disappearing or getting replaced with something more specific in the weeks around 27 September, that shift itself is a signal the property is taking this seriously. Watch too for whether any ‘carbon neutral’ claims persist unchanged, since those are banned outright regardless of substantiation, and their survival past the deadline says something about how closely a property is paying attention. And if a certification is named, it’s worth tracing whether it actually leads back to a real, checkable scheme rather than a logo with no accreditation trail behind it.
None of this means avoid properties that use sustainability in their marketing, most aren’t trying to deceive anyone, and plenty have real credentials behind their claims already. It just means the next few weeks are a genuinely useful moment to look a little closer than usual, since for the first time, the law is looking closer too.
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