*By Kyros Asfis
The era when sustainability was merely a marketing tool or a “nice initiative” for hotels has irrevocably passed. From September 2026, the landscape changes radically.
With two pivotal legislative acts, the Directive on Empowering Consumers for the Green Transition (ECGT – EU 2024/825) and the Regulation on ESG Ratings (EU 2024/3005), the European Union sets strict rules regarding the use of sustainability-related terms in hotel marketing. This is no longer a simple compliance recommendation, but law.
For the Greek hotelier, the message is clear: Either you prove your claims, or you remove them.
Let us examine what is changing and how you must adapt.
Before beginning the analysis of what the new European Union legislation describes and imposes, I will cite certain examples of how the term sustainability has been used in hotel marketing until now.
The Phenomenon of Greenwashing: A Brief Retrospective on How It Was Applied
To better understand the issue being analyzed, let us begin with the definition of Greenwashing.
Greenwashing is the practice whereby a business spends more time and money advertising that it is “green” than implementing substantive environmental practices. It is the creation of a misleading image of ecological sensitivity.
In the hotel sector, Greenwashing found fertile ground for decades. The most common practices now being targeted by the European Union were:
- The “Towel Trick”: The classic card in the bathroom: “Help us save the planet, reuse your towel.” Although positive as an action, it was often the hotel’s only action, using ecology as a pretext for reducing operational costs (laundry costs), without reinvesting those savings back into environmental initiatives.
- The Aesthetic of Nature: The use of earth-tone colors, wooden decorations, and forest imagery on the website to create the impression of an “Eco-Resort,” while the building might not even have basic insulation or waste management.
- Vague Promises: Phrases such as “We respect the environment” or “Nature is our philosophy,” which sound appealing but do not commit the business to any measurable action.
These practices created distrust among travelers. The EU now comes to restore this trust in a particularly strict manner.
I will therefore begin by outlining the new legislation imposed by the European Union from September 2026 regarding the use of sustainability-related terms in hotel marketing.
1. Prohibition of the Use of General Environmental Terms
What is Defined as a “General Claim”:
As a general definition, any statement that presents or implies environmental excellence without referring to a specific, measurable characteristic (e.g., the use of words such as “eco,” “green,” “environmentally friendly”) is considered a general claim.
Under the ECGT Directive, vague environmental claims are prohibited unless accompanied by proof of “recognized excellent environmental performance” (e.g., EU Ecolabel certification or national ISO 14024 Type I schemes).
Words such as “Green,” “Eco-friendly,” “Climate friendly,” “Sustainable,” “Nature-friendly” are blacklisted if used in general terms without specific documentation.
2. Claims of Climate Neutrality Based on Offsetting Are Not Acceptable
What is Offsetting:
Offsetting is defined as the practice of purchasing carbon credits from third-party projects (e.g., reforestation on other continents) to compensate for the emissions produced by the business itself, without necessarily reducing them.
Perhaps the most significant change: It is prohibited to claim that the hotel or the stay is “climate neutral,” “carbon positive,” or “net zero” if this is based on emissions offsetting outside the hotel’s own operational activity.
Let us consider some practical examples of correct and incorrect application:
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3. Mandatory Third-Party Certification & Abolition of Private Labels
Let us begin with the definition of what constitutes a “Sustainability Label.”
A sustainability label is any voluntary trust mark, quality label, or equivalent symbol (logo), public or private, intended to distinguish a product or trader based on environmental characteristics.
It is prohibited to display sustainability labels that are not based on a certification scheme with strict criteria or that have not been established by public authorities.
What this means in practice:
- End of “Self-made” Labels: You cannot design your own logo (e.g., “Hotel X Green Approved”) and place it on your website.
- Independence: The entity owning the label must be legally separate from the certification auditor.
- Transparency: The certification criteria must be publicly available online.
Attention: If you have certification from a private body where it is unclear who audits whom, or if the criteria are not clearly defined, the label must be removed by September 2026.
4. Legal Restrictions on the Use of Nature Imagery (Visual Greenwashing)
What is Visual Greenwashing:
Visual Greenwashing is the use of images, colors, or symbols (tree leaves, forests, the blue planet) that create associative impressions of environmental benefit, without corresponding to the actual impact of the business.
The legislation does not concern only text. Images such as green leaves, water droplets, forests, or colors associated with nature, when combined with vague messaging, are considered “implicit environmental claims.”
- The Problem: A banner on the booking engine with a forest background and the phrase “Stay Naturally,” without documentation, is misleading.
- The Solution: The visual presentation must be honest. Do not use “green” imagery unless there is corresponding “green” performance.
5. Practical Examples of Compliance & Violations
How do the above translate into the daily work of the Marketing department? Below are three scenarios:
Scenario A: The “Green” Renovation
- WRONG: “Discover our new ecological wing! The most sustainable accommodation, built with respect for nature.” (Vagueness, superlative without proof.)
- CORRECT: “Our new wing features A+ energy class certification and flooring made from 100% recycled wood.” (Specific technical characteristics.)
Scenario B: Single-Use Plastics
- WRONG: “Plastic-Free Hotel. We save the oceans.” (False if even minimal plastics exist, e.g., pens or kitchen wrapping film.)
- CORRECT: “We eliminated plastic water bottles in rooms and the restaurant, reducing waste by 15,000 units annually.” (Precise scope of application.)
Scenario C: Self-Evident Benefits
- WRONG: “Our hotel is CFC-free and uses lead-free paints.”
- CORRECT: (Nothing). Explanation: It is prohibited to advertise as a “sustainability advantage” something already required by law (CFCs have been banned for decades). It is misleading.
6. New Transparency Framework for ESG Ratings
What is an ESG Rating:
An ESG rating is a score assigned by an external body that evaluates a company’s profile in Environmental, Social, and Governance matters, affecting access to financing.
Regulation (EU) 2024/3005 mainly concerns your relationship with investors and banks. It ensures that ESG ratings are reliable.
If you use ESG scores to attract investments or corporate clients, ensure that the rating provider is approved and does not simultaneously sell you consulting services (conflict of interest).
What You Must Do NOW (Checklist)
By September 2026, you must have completed the following actions:
- Material Audit: Review website, brochures, social media, lobby signage, and key cards. Are there words such as “eco,” “green,” “nature” without documentation?
- Certification Review: Do the labels you display meet EU criteria (independence, transparency)? If not, they must be removed.
- Data Collection: Replace adjectives with numbers. Instead of “energy savings,” identify the percentage reduction from your utility bills.
- Staff Training: The Marketing and Sales teams must learn the new communication code.
Frequently Asked Questions (FAQ) on the New Legislation
1. When do the new regulations enter into force?
The ECGT Directive (Empowering Consumers for the Green Transition) must be fully implemented by 27 September 2026.
2. I already have certification (e.g., Green Key, Travelife). Am I covered?
Not necessarily. You must verify whether your label meets the new strict EU criteria, particularly regarding the independence of the auditor from the label owner.
3. Can I say that I plant trees to offset guest emissions?
You may communicate the action, but you may NOT use it to claim that the hotel is “Climate Neutral.”
4. Does the law apply to small hotels and Airbnb?
Yes. The legislation applies to all hospitality activities regardless of size.
Conclusion: Honesty as the New Competitive Advantage
The EU’s ECGT and ESG regulations have arrived to cleanse a market that for years operated under conditions of “green ambiguity.”
From September 2026 onward, the competitive advantage will not belong to the one with the best slogan, but to the one with the most reliable data. The transition from “Storytelling” to “Storydoing” is a one-way path.
For the modern hotelier, this is a unique opportunity. By removing the noise of Greenwashing, genuine investments in sustainability will shine. The public is now informed and seeks the truth. Provide it—documented and measurable—and you will gain the most difficult currency of our era: trust.
Source: kyrosasfis.com