Enforced since 27 September 2026 · EU Directive 2024/825 (EmpCo)
“Our destination is sustainable.”
Five words that appear on destination websites everywhere. Since 27 September 2026, regulators across the EU treat them as a high-risk claim.
“75% of hotels are certified by recognised sustainability schemes, with full destination coverage targeted by 2027.”
The same ambition, stated as proof: a specific figure, a defined scope, independent certification and a target with a date.
Claims and labels: European Commission (2020), Environmental claims in the EU. Fines: Proof, Not Promises, p.12.
1 · The test
Eight letters every claim now has to pass
Regulators judge the overall impression a claim gives a reasonable consumer, not only its technical accuracy. The guide turns that into eight principles that spell CREDIBLE. Pick a letter to see how our sentence does.
C · Clear
Claims must be understandable, accurate, and not misleading.
Use plain language, avoid exaggeration, and ensure the overall impression is not misleading to a reasonable consumer.
Sustainable in what way? A reasonable visitor cannot tell what is being claimed.
Ten words that now need proof
The R in CREDIBLE · p.10- Environmentally friendly
- Eco-friendly
- Green
- Climate friendly
- Carbon friendly
- Sustainable
- Environmentally responsible
- Biodegradable
- Biobased
- Non-toxic
These are generic environmental claims: they suggest a product, service or organisation is good for the environment without saying what the benefit is. Under EmpCo they are prohibited unless backed by recognised excellent environmental performance relevant to the claim. The same goes for similar expressions.
2 · The rewrite
Same ambition. Stated as proof.
Five claims regulators are likely to read as high-risk, and how the guide reframes each one. The last row is our sentence.
Why our sentence is so risky for a destination
A destination-level claim covers hotels, venues, transport providers and suppliers that the DMO often has little direct control over. To back it up, a DMO needs:
- Reliable, destination-wide data
- A clear definition of scope and boundaries
- Alignment across multiple stakeholders
Without this, partial performance or isolated initiatives end up presented as the whole destination.
From destination branding to destination accountability.
Public ownership is no exemption. A DMO that sells or markets tickets, city cards, tours or experiences to visitors can count as a trader under consumer law.
Sources: Proof, Not Promises, p.13 and p.14.
3 · The map
Same law. Different routes into national law.
Every EU country must turn the Directive into national law, but they are doing it in different ways. In some, the rules sit mainly in existing consumer law. In others, they are spread across several laws. Pick a country.
Denmark
Model 02Implementation across several laws
The requirements are distributed across different laws covering consumer protection, contracts, advertising or unfair competition. Organisations may need to consult more than one law to understand the rules governing their sustainability communications.
Proof, Not Promises, p.11, updated 27 October 2026. The classifications reflect the main approach to national implementation, not every related amendment. Malta, Portugal, Slovenia, Spain and Sweden remain outside the classifications while their status is confirmed. Poland has adopted its law but applies it from 27 September 2027. For the latest, consult the EU’s national transposition measures database.
Already challenged
These companies were challenged under existing consumer, advertising and competition law, before EmpCo. They signal the direction for tourism and events: claims will be challenged not only when false, but when they are vague, comparative or insufficiently evidenced.
Source: Proof, Not Promises, p.12.
4 · What changes on Monday
If you can’t prove it, don’t say it.
Your bid is now an advert.
Bids, proposals, and RFP responses should be subject to the same evidence standards as public-facing communications.
Proof, Not Promises, p.21Your supplier’s green claim just became yours.
Claims made by partners, suppliers, or venues may create risk where they are repeated, endorsed, or incorporated into an organisation’s own communications.
Proof, Not Promises, p.20Offsets alone won’t carry a “net zero” claim.
Do not rely on offsetting alone to justify absolute environmental claims.
Proof, Not Promises, p.21“Net zero by 2030” needs a plan, not a slogan.
Future commitments must be credible, documented, and supported by clear plans.
Proof, Not Promises, p.20Ambition is not evidence.
Sustainability claims should reflect measured performance, not ambition or intent.
Proof, Not Promises, p.21Keep the receipts.
Maintain accessible, up-to-date records to ensure evidence can be provided if claims are challenged.
Proof, Not Promises, p.20“Low-carbon” now comes with a footnote.
Claims such as “low-carbon”, “climate neutral” or “net zero” require careful qualification and clear explanation.
Proof, Not Promises, p.21Carbon, waste, circularity: say where the line is.
Claims relating to carbon, waste, and circularity must clearly define scope, boundaries, and methodology.
Proof, Not Promises, p.20Updated edition · October 2026
Read the full guide
Proof, Not Promises explains the Directive, how each EU country is implementing it, what makes a certification credible and how travel platforms are already enforcing evidence. Published by GDS-Movement with the European Travel Commission and NECSTouR.
New in this edition
- How EmpCo is being implemented across the EU, where national approaches differ and where enforcement risks are highest
- Clearer guidance on how the rules apply to DMOs, public bodies, tourism businesses, event organisers and NTOs
- Clearer guidance on high-risk claims, climate commitments and greenwashing, with eight principles for credible communication
- A closer look at certification: what makes a label credible, and why independent verification and accreditation matter
Choose your next step
Based on Directive (EU) 2024/825 and a review of final and draft national transposition measures, as of 27 October 2026. A practical interpretation, not legal advice.

