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.

Put the sentence on trial Download the guide
53%
of environmental claims in the EU were vague, misleading or unfounded
40%
were unsubstantiated
1 in 2
environmental labels had weak or no verification
4%
of annual turnover: potential fines under the Directive framework, at least

Claims and labels: European Commission (2020), Environmental claims in the EU. Fines: Proof, Not Promises, p.12.

Published by

Global Destination Sustainability Movement European Travel Commission NECSTouR – European Regions for Competitive and Sustainable Tourism

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.

Testing
“Our destination is sustainable.”

C · Clear

Requirement

Claims must be understandable, accurate, and not misleading.

What this means in practice

Use plain language, avoid exaggeration, and ensure the overall impression is not misleading to a reasonable consumer.

Fails

Sustainable in what way? A reasonable visitor cannot tell what is being claimed.

The promise fails 6 of 8 principles. Principles from Proof, Not Promises, p.09. The verdicts are an illustration, not legal advice.

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.

From vague to specific
High-risk
“Our hotel is the most sustainable in the region”
Credible
“Our hotel uses 100% renewable electricity and has reduced water use by 30% since 2021”
From subjective to objective and verifiable
High-risk
“Our destination is the most sustainable in the world”
Credible
“Ranked first in the 2025 Global Destination Sustainability Index”
From headline claims to evidence-based communication
High-risk
“Our event is net zero”
Credible
“The event’s carbon footprint was measured, emissions were reduced by 38%, and remaining emissions were addressed through certified offsetting schemes”
From self-declared labels to independent verification
High-risk
“GreenConscious eco-certified hotel”
Credible
“This hotel is certified by EarthCheck, which audits it annually”
Our sentenceFrom partial action to accurate scope
High-risk
“Our destination is sustainable”
Credible
“75% of hotels are certified by recognised sustainability schemes, with full destination coverage targeted by 2027”
The pattern Broad claims → specific metrics Opinion → recognised benchmarks Statements → evidence and method Self-declared → third-party verified Over-claiming → defined scope

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.

Key shift for DMOs · p.14

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.

Into consumer law (12) Across several laws (10) Status to be confirmed (5) Applies later

Denmark

Model 02
How it is written into law

Implementation 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.

2024Booking.comEU scrutiny of its “Travel Sustainable” label raised concerns about transparency, methodology and the potential to mislead. It has since changed its practices to support the Directive.
2024KLMA Dutch court found elements of its “Fly Responsibly” campaign misleading, particularly where environmental benefits were overstated.
2020RyanairChallenged over claims of being “Europe’s lowest emissions airline”, where the comparisons lacked sufficient substantiation.
2024H&MFaced regulatory scrutiny over its “Conscious” collection, particularly the clarity and credibility of its sustainability scoring.

Source: Proof, Not Promises, p.12.

4 · What changes on Monday

If you can’t prove it, don’t say it.

Event organisers

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.21
Tourism businesses

Your 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.20
Event organisers

Offsets alone won’t carry a “net zero” claim.

Do not rely on offsetting alone to justify absolute environmental claims.

Proof, Not Promises, p.21
Tourism businesses

“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.20
Event organisers

Ambition is not evidence.

Sustainability claims should reflect measured performance, not ambition or intent.

Proof, Not Promises, p.21
Tourism businesses

Keep the receipts.

Maintain accessible, up-to-date records to ensure evidence can be provided if claims are challenged.

Proof, Not Promises, p.20
Event organisers

“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.21
Tourism businesses

Carbon, 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.20

Updated 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.

Download the guide

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

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.