Directive (EU) 2024/825 — Empowering Consumers for the Green Transition (ECGT)
Say this, not that
The September 2026 language matrix
Prohibited vs compliant claims
Prohibited / high risk post-Sept 2026Generic, unverified or offset-based wording
Legally compliant alternativeSpecific, evidenced, verifiable wording
Prohibited / high risk
“Eco-friendly hotel” / “Environmentally friendly”
Generic environmental claims are prohibited unless recognised excellent environmental performance relevant to the claim can be demonstrated.
Compliant
Use only where recognised excellent environmental performance can be demonstrated
The ECGT does not require third-party certification for these textual claims — but independent certification (such as FuturePlus) provides strong, credible supporting evidence.
Prohibited / high risk
“100% carbon neutral stay” / “Climate neutral”
Neutral, reduced or positive impact claims based solely on carbon offsetting or credits outside the business’s own value chain are prohibited.
Compliant
“We have reduced our operational emissions by X% since [baseline year]”
State measured reductions against a named baseline, with progress measured and reported annually.
Prohibited / high risk
“Net zero by 2030”
Unsupported future claims are prohibited — commitments must be clear, objective and publicly available, with measurable, time-bound targets.
Compliant
“Committed to net zero by 2030, supported by a publicly available transition plan”
With interim milestones, defined actions and regular progress reporting — plus independent monitoring where required.
Prohibited / high risk
Self-created “Planet First” badge / logo
Sustainability labels not based on a certification scheme or established by a public authority are prohibited — self-created badges are no longer permitted.
Compliant
A recognised certification scheme or official public sustainability label
For example, an independently governed certification such as FuturePlus, or the EU Ecolabel where applicable.
Compliance checklist for hoteliers
1. Audit touchpoints
Audit all B2C environmental marketing and collateral — direct website, OTA channels, in-stay materials and ad copy — across every EU market you sell into.
2. Implement third-party verification
Any sustainability label must be based on a certification scheme or established by a public authority; for textual claims, independently verified certification provides robust supporting evidence.
3. Protect OTA distribution
Booking platforms and initiatives such as Travalyst are moving to recognised, independently verified certifications — without credible evidence, properties risk losing visibility in sustainability filters and corporate travel programmes.
Horwath HTL × FuturePlus — The September 2026 line in the sand
Say this, not that: the September 2026 language matrix under the EU Empowering Consumers for the Green Transition Directive (Directive (EU) 2024/825), applying from 27 September 2026. Prohibited or high risk: generic claims such as eco-friendly hotel or environmentally friendly, unless recognised excellent environmental performance relevant to the claim can be demonstrated; 100% carbon neutral stay or climate neutral claims based solely on carbon offsetting or credits outside the business's own value chain; net zero by 2030 without supporting commitments; and self-created sustainability badges or logos. Legally compliant alternatives: use generic terms only where recognised excellent environmental performance can be demonstrated, with independent certification such as FuturePlus as supporting evidence; state operational emissions reduced by a percentage since a baseline year with annual measured reporting; commit to net zero supported by a publicly available transition plan with interim milestones, defined actions and regular progress reporting; and use a recognised certification scheme or an official public sustainability label such as the EU Ecolabel. Three-step compliance checklist: audit touchpoints, implement third-party verification, protect OTA distribution. Horwath HTL and FuturePlus.
Prohibited / high risk (post-Sept 2026)Legally compliant alternative
"Eco-friendly hotel" / "Environmentally friendly"Use only where recognised excellent environmental performance can be demonstrated; independent certification (e.g. FuturePlus) provides supporting evidence
"100% carbon neutral stay" / "Climate neutral""We have reduced our operational emissions by X% since [baseline year]", measured and reported annually
"Net zero by 2030" (unsupported)Net zero commitment supported by a publicly available transition plan with interim milestones, defined actions and regular progress reporting
Self-created "Planet First" badge / logoA recognised certification scheme (e.g. FuturePlus) or official public sustainability label (e.g. EU Ecolabel)