EU Directive 2024/825 (Green Claims Directive): What It Means for Hotels and Tour Operators
For years, hospitality marketing relied on broad, feel-good sustainability claims. Terms like “eco-friendly,” “green stay,” and “carbon-neutral” are standard across booking engines and brochures. However, the European regulatory landscape is shifting. If you operate a hotel, lodge, or tour operator business marketing to European consumers, understanding **what is EU Directive 2024/825** is now essential. This directive, alongside the broader EU green claims framework, marks the end of self-declared, unverified environmental claims in the European market.
Directive 2024/825 in 60 seconds
If you are short on time, here is the operational summary of how Directive (EU) 2024/825 impacts your business:
Scope of Ban:
Generic environmental claims (such as “eco-friendly,” “sustainable,” “green”) are prohibited on consumer-facing platforms unless supported by recognized environmental performance (like the EU Ecolabel) or highly specific, pre-verified evidence.
Offset Prohibition:
You can no longer claim a stay is “carbon-neutral” or “CO2-compensated” based on carbon offsets.
Enforcement Timeline:
Member states must apply the national transposing laws by September 27, 2026
Third-Party Certification:
Sustainability labels and claims must be verified by independent, accredited third-party schemes.
Extra-territorial Reach:
The rules apply to any hospitality operator targeting EU consumers, regardless of the property’s physical location.
Fines:
Non-compliance carries penalties including fines of up to 4% of annual turnover, exclusion from public procurement, and the confiscation of revenues.
What is the EU Green Claims Directive? (And what is EU Directive 2024/825?)
To understand this regulatory push, we must separate two legislative initiatives introduced by the European Commission: the Empowering Consumers for the Green Transition (ECGT) Directive (Directive (EU) 2024/825) and the proposed Green Claims Directive.
Both are part of the EU’s Circular Economy Action Plan and the European Green Deal, designed to eradicate greenwashing and give consumers reliable information to make ecological decisions.
Directive (EU) 2024/825 modifies two fundamental pillars of EU consumer protection law: the Unfair Commercial Practices Directive (UCPD) (Directive 2005/29/EC) and the Consumer Rights Directive (Directive 2011/83/EU). The UCPD regulates B2C advertising and commercial behavior in Europe. By amending it, the EU has added specific greenwashing practices to the “black list” of commercial practices banned under all circumstances.
The DG JUST (Directorate-General for Justice and Consumers) is the driving force behind this regulatory wave. Their position is clear: the market is saturated with self-declared, unverified green claims that confuse consumers and disadvantage truly sustainable businesses. DG JUST is forcing a transition from voluntary, self-policed marketing to a regulated, verified compliance framework.
How it relates to the Empowering Consumers Directive (Dir 2024/825 vs 2024/825 timeline confusion)
There is significant timeline confusion in the hospitality sector regarding these two directives. Many hotel groups and tour operators are delaying compliance because they believe the “Green Claims Directive” has faced legislative pauses or is not enforced until 2027 or 2028. This is a critical error.
Directive 2024/825 (the Empowering Consumers Directive) is already adopted. It entered into force on March 26, 2024. Member states are transposing it into national law, and the enforcement date of September 27, 2026, is locked in.
The proposed Green Claims Directive is a complementary piece of legislation. It goes into greater detail regarding the specific methodologies required to substantiate claims and the framework for third-party verifiers. While the Green Claims Directive proposal is still moving through the legislative process, Directive 2024/825 is law today.
The ban on generic claims, carbon offsetting claims, and unverified eco-labels will apply from September 2026. Delaying preparation because of “timeline confusion” between these two pieces of legislation puts your business at immediate legal risk.
Who enforces it and which national authorities lead in each member state
Because Directive 2024/825 is an EU Directive, it does not apply directly as a single federal law. Instead, each of the 27 EU member states must transpose the directive’s requirements into their own national legal frameworks. This means enforcement will be handled by the **national competent authorities** in each member state.
These national regulators already enforce consumer protection laws and are preparing to police hospitality claims aggressively:
France: The DGCCRF (Direction générale de la concurrence, de la consommation et de la répression des fraudes) is active in prosecuting greenwashing. The authority monitors hotel websites, booking platforms, and print brochures to ensure compliance.
Germany: Enforcement is driven by the Verbraucherzentralen (consumer protection associations) and competitive bodies such as the Wettbewerbszentrale, which can bring civil cease-and-desist actions against misleading environmental claims.
Netherlands: The ACM (Authority for Consumers and Markets) has issued detailed sustainability claim guidelines and has actively audited and fined travel and hospitality businesses for non-compliance.
Sweden: The Konsumentverket (Swedish Consumer Agency) oversees compliance and has the authority to issue injunctions and impose fines where necessary.
Ireland: The CCPC (Competition and Consumer Protection Commission) serves as the primary enforcement body for consumer protection and greenwashing regulations.
Italy: The AGCM (Autorità Garante della Concorrenza e del Mercato) enforces the transposing legislation and has the power to levy administrative fines for violations.
These national competent authorities will perform active market sweeps—using automated web scrapers to audit hotel booking channels and websites for forbidden terms.
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Who enforces it and which national authorities lead in each member state
Many hoteliers assume green claims regulations target only consumer goods. In reality, the hospitality sector is under intense scrutiny. From “carbon-neutral” stays to “eco-lodges,” environmental claims are heavily marketed to high-yield travelers. Because tourism is inherently resource-intensive (transport, heating, waste), consumer protection agencies are actively monitoring hotel marketing.
"Eco", "green", "sustainable", "carbon-neutral" — claims that are now regulated
Under Directive 2024/825, any environmental claim must be specific, clear, and substantiated. The directive’s target list includes several terms that are currently standard in hotel copy:
- “Eco-hotel” or “Eco-lodge”: You can no longer call your property an “eco-hotel” or “eco-lodge” as a general descriptor unless the entire establishment holds a recognized third-party certification (such as the EU Ecolabel) that covers all aspects of the operation.
- “Green stay”: This is a generic claim. If you offer a “green stay” option on your booking engine (for example, opting out of daily housekeeping), you must specify exactly what environmental benefits this choice yields (e.g., “reduces water consumption by 40 liters and detergent use by 15 grams per room-night”). Simply labeling it “green” is prohibited.
- “Sustainable tourism”: The term “sustainable” implies a holistic state of zero or positive impact. Because no commercial hotel operation is truly sustainable in the absolute sense, using this term without a highly specific, verified framework may constitute a direct violation.
- “Carbon-neutral stays”: Many hotels offer guests the option to pay an additional fee to make their stay “carbon-neutral.” The directive explicitly prohibits claims that a service has a neutral, reduced, or positive environmental impact regarding greenhouse gas emissions when those claims rely solely on offsetting emissions. You cannot claim your hotel is “carbon-neutral” or that a room-night is “offset” if the claim depends on purchasing carbon credits. Carbon neutrality may only be claimed where net-zero emissions have been achieved through direct operational reductions (Scope 1, 2, and 3) verified by rigorous third-party auditing.
B2C vs B2B claims and why hotel websites are treated as B2C
Some hotel operators believe sustainability claims intended for corporate travel procurement (B2B) are exempt from consumer protection laws. However, if these claims appear on public websites, booking engines, or OTA listings, they reach individual consumers and are classified as B2C practices under the UCPD. Even if your focus is corporate contracts, public claims must comply. Furthermore, corporate procurement teams now use these EU rules to evaluate vendors; if your hotel cannot substantiate its claims, you risk exclusion from preferred supplier lists to protect their Scope 3 reporting compliance.
Key Claims Required
The 6 substantiation requirements every hotel claim must now pass
To ensure compliance, any environmental claim made by a hotel or tour operator must pass a series of strict verification filters. These filters are designed to prevent the common practice of cherry-picking minor positive actions while ignoring major negative impacts.
Every claim you make—whether it’s on your website, a placard in the guest bathroom, or a slide in a corporate sales deck—must meet the following six substantiation requirements:
Rely on Recognized Scientific Evidence and State-of-the-Art Technical Knowledge
Your claims cannot be based on internal assumptions or anecdotal evidence. If you claim that your heat-pump system reduces carbon emissions, you must have engineering data, manufacturer certifications, and actual energy bills to prove it. The evidence must be current, scientifically sound, and open to inspection.
Demonstrate a Life-Cycle Perspective
You cannot claim that a service is “green” based on a single, isolated phase of its life cycle if the overall impact of the service is negative. For instance, a hotel cannot claim its restaurant is “zero waste” if it only measures waste at the table, ignoring the significant food waste generated during preparation or the packaging waste from suppliers. You must look at the entire lifecycle of the service.
Account for All Significant Environmental Impacts
Cherry-picking is the practice of highlighting one positive environmental attribute to distract from a major negative one. For example, a resort cannot advertise a “plastic-free room” if that room is heated by an inefficient, high-emission diesel boiler. The claim must not mislead the consumer by failing to mention that the positive impact is offset by a massive negative impact in another area.
Distinguish Performance Relative to Legal Minimums or Standard Practice
You cannot claim environmental credit for doing what the law already requires you to do. For example, if a local regulation bans single-use plastic toiletry bottles in hotels, you cannot advertise “We are eco-friendly because we do not use single-use plastics.” This is simply regulatory compliance, not an environmental benefit.
Clearly Specify the Scope of the Claim
Many hotel claims suffer from scope ambiguity. When a hotel website says “Our hotel is 100% sustainable,” does that apply to the physical building, the daily operations, or the restaurant? Under the new rules, you must clearly specify the exact scope of your claim. If your energy is 100% renewable, you must state whether this applies to electricity, heating, or both, and which buildings it covers.
Subject the Claim to Independent, Accredited Third-Party Verification
Self-declared environmental claims or labels designed by the hotel itself are prohibited. Every environmental claim and sustainability label must be verified by an independent, accredited third-party verifier before it is published. This verifier must be a recognized certification body that operates under established international standards (such as ISO 14024 for eco-labels) or is officially recognized by public authorities (such as the EU Ecolabel, Green Key, or EarthCheck).
Read More on wHat is expected
Need to ensure you are checking all requirements boxes?
Key dates — what must be true by September 2026
The timeline for compliance is tight:
March 6, 2024: Directive 2024/825 was officially published.
March 27, 2026: Member states must adopt transposing national laws.
September 27, 2026: Transposed national laws are fully applied.
By September 2026, your business must have:
1. Removed all generic claims not backed by official certifications.
2. Removed offset-based carbon-neutral options from booking engines.
3. Transitioned to accredited third-party eco-labels.
4. Compiled substantiation dossiers for all specific claims.
5. Updated B2B RFP templates to meet new legal standards.
What changes for non-EU operators selling to EU consumers
If your hotel, lodge, or tour operation targets EU consumers, you must comply. The European Commission and national regulators apply consumer protection laws based on the consumer’s location.
Indicators of targeting EU consumers include:
* Offering websites in European languages.
* Quoting prices in Euros (EUR) or other EU currencies.
* Directing digital ad campaigns at users located in the EU.
* Partnering with EU-based travel distributors.
Regulators can fine your EU-based sales partners or force booking platforms (OTAs) to remove non-compliant listings. To understand the specific compliance challenges, read our deep dive:
First 5 actions to take this quarter
We recommend executing the following five actions this quarter to build a compliant foundation:
Action 1: Conduct a Comprehensive Marketing Audit
Inventory all environmental claims on websites, booking engines, OTAs, social media, and guest collateral.
Action 2: Review and Rationalize Eco-Labels and Certifications
Audit existing certifications. Ensure they are issued by independent, accredited organizations following ISO 14024.
Action 3: Audit and Restructure Carbon Offsetting Programs
Disable options allowing guests to purchase offset-based "carbon-neutral stays" and rewrite the copy to be transactional.
Action 4: Build a Centralized Substantiation Dossier
Compile supplier invoices, energy certificates, and independent audits for every claim you keep.
Action 5: Align Marketing, Legal, and Procurement Teams
Establish a clear internal approval process for new claims and coordinate purchasing with operational data.
FAQs:
Here are the most common questions we receive from hospitality operators:
Does this apply to my hotel if I'm based outside the EU?
Yes. If you target EU consumers, you must comply. Non-EU companies are subject to enforcement via their European distribution channels and sales partners.
What's the fine for non-compliance?
Penalties are severe. Cross-border violations carry maximum fines of at least 4% of the annual turnover in the affected member states.
Regulators can also confiscate revenues and exclude businesses from public contracts. Read more in Legal Consequences of Non-Compliant Green Claims in the EU
Do I need an audit before September 2026?
The law does not mandate a pre-deadline government audit. However, conducting an audit is a critical risk-management step to identify and remove non-compliant claims.
You can start this process today by using our free EU Compliance Audit Tool
Where to go next
Start with our free self-assessment:
Use our EU Compliance Audit Tool to scan your public claims and receive an immediate risk report. It takes less than 10 minutes and will highlight the most critical areas.
Ready to build a robust compliance strategy?
If you manage a hotel group, resort portfolio, or destination management company and need a comprehensive compliance framework, let’s discuss your requirements. Book a Strategy Consultation with our sustainability compliance specialists.
We will help you audit operations, align marketing, and build the substantiation dossiers necessary to protect your business.
