*By Kyros Asfis
The days when sustainability was merely a marketing tool or a “nice initiative” for hotels are now irrevocably behind us. From September 2026, the landscape will change radically.
With two key pieces of legislation, 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 has laid down strict rules regarding the use of sustainability-related terms in hotel marketing. This is no longer merely a compliance recommendation, but law.
For Greek hoteliers, the message is clear: either you substantiate your claims, or you withdraw them.
Let us look at what is changing and how you need to adapt.
Before beginning the analysis of what the new European Union legislation sets out and requires, I shall give some examples of how the term ‘sustainability’ has been used in hotel marketing to date.
The Phenomenon of Greenwashing: A Brief Retrospective on How It Was Applied
To gain a better understanding of the issue under discussion, let us begin by defining ‘greenwashing’.
Greenwashing is the practice whereby a business spends more time and money advertising that it is “green” than actually implementing meaningful environmental measures. It involves creating a misleading impression of environmental awareness.
In the hotel sector, greenwashing has found fertile ground for decades. The most common practices now being targeted by the European Union were:
- The “Towel Trick”: The classic sign in the bathroom: “Help us save the planet, reuse your towel.” Although this was a positive initiative in itself, it was often the hotel’s only measure, using environmental concerns as a pretext for reducing operational costs (laundry costs), without reinvesting those savings in environmental initiatives.
- The Aesthetics of Nature: The use of earth-tone colours, wooden decorations and forest imagery on the website to create the impression of an “Eco-Resort”, whilst the building may not even have basic insulation or a waste management system.
- 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 have led to a loss of trust amongst travellers. The EU is now taking particularly strict measures to restore that trust.
I shall therefore begin by outlining the new legislation introduced by the European Union with effect from September 2026 concerning the use of sustainability-related terms in hotel marketing.
1. Prohibition on 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” or “environmentally friendly”) is considered a general claim.
Under the ECGT Directive, vague environmental claims are prohibited unless supported by evidence of “recognised excellent environmental performance” (e.g. EU Ecolabel certification or national ISO 14024 Type I schemes).
Words such as “Green”, “Eco-friendly”, “Climate-friendly”, “Sustainable” and “Nature-friendly” are blacklisted if used in general terms without specific supporting evidence.
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 offset the emissions produced by the business itself, without necessarily reducing them.
Perhaps the most significant change is that 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 activities.
Let us consider some practical examples of correct and incorrect application:
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3. Mandatory Third-Party Certification and the Abolition of Private Labels
Let us begin by defining what constitutes a “sustainability label”.”
A sustainability label is any voluntary trust mark, quality label or equivalent symbol (logo), whether public or private, intended to distinguish a product or trader on the basis of 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:
- The End of “Self-made” Labels: You cannot design your own logo (e.g. “Hotel X Green Approved”) and display it on your website.
- Independence: The entity that owns the label must be legally separate from the certification auditor.
- Transparency: The certification criteria must be publicly available online.
Please note: If you hold 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, colours or symbols (tree leaves, forests, the blue planet) that create an impression of environmental benefit, without this corresponding to the business’s actual impact.
The legislation does not apply solely to text. Images such as green leaves, water droplets, forests or colours associated with nature, when combined with vague messaging, are considered “implicit environmental claims”.”
- The Problem: A banner on the booking engine featuring a forest background and the phrase “Stay Naturally”, without any supporting information, is misleading.
- The Solution: The visual presentation must be truthful. Do not use “green” imagery unless there is corresponding “green” performance.
5. Practical Examples of Compliance and Breaches
How do the above translate into the day-to-day work of the Marketing department? Below are three scenarios:
Scenario A: The “Green” Renovation
- WRONG: “Discover our new eco-friendly wing! The most sustainable accommodation, built with respect for nature.” (Vague, superlative without evidence.)
- CORRECT: “Our new wing has an A+ energy rating and flooring made from 100% recycled wood.” (Specific technical characteristics.)
Scenario B: Single-use plastics
- WRONG: “Plastic-Free Hotel. We save the oceans.” (This is false if even the slightest amount of plastic is present, e.g. pens or cling film.)
- CORRECT: “We have phased out plastic water bottles in guest rooms and the restaurant, reducing waste by 15,000 units a year.” (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 that is already required by law (CFCs have been banned for decades). This is misleading.
6. New Transparency Framework for ESG Ratings
What is an ESG rating:
An ESG rating is a score awarded by an external body that assesses a company’s performance in environmental, social and governance matters, which affects its access to finance.
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 investment or corporate clients, ensure that the rating provider is authorised and does not simultaneously provide you with consultancy services (conflict of interest).
What You Must Do NOW (Checklist)
By September 2026, you must have completed the following tasks:
- Material Audit: Review the website, brochures, social media, lobby signage and key cards. Are there any terms such as “eco”, “green” or “nature” used without supporting evidence?
- 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”, state the percentage reduction shown on your utility bills.
- Staff Training: The Marketing and Sales teams must learn the new communication guidelines.
Frequently Asked Questions (FAQ) on the New Legislation
1. When do the new regulations come into force?
The ECGT Directive (Empowering Consumers for the Green Transition) must be fully implemented by 27 September 2026.
2. I already hold a certification (e.g., Green Key, Travelife). Am I covered?
Not necessarily. You must check whether your label meets the new, strict EU criteria, particularly with regard to the auditor’s independence from the label owner.
3. Can I say that I plant trees to offset emissions caused by guests?
You may publicise the initiative, but you must 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 businesses, regardless of their size.
Conclusion: Honesty as the New Competitive Advantage
The EU’s ECGT and ESG regulations have been introduced to clean up a market that for years operated under conditions of “green ambiguity”.”
From September 2026 onwards, the competitive advantage will not lie with whoever has the best slogan, but with whoever has the most reliable data. The transition from “Storytelling” to “Storydoing” is a one-way street.
For the modern hotelier, this is a unique opportunity. By cutting through the noise of greenwashing, genuine investments in sustainability will come to the fore. The public is now well-informed and seeks the truth. Provide it—documented and measurable—and you will earn the most elusive currency of our time: trust.
Source: kyrosasfis.com