Sustainability Communication in Tourism: EmpCo Guide

Regulatory Frameworks and Standards

At the core of the regulatory frameworks governing modern sustainability communication is the Directive on Empowering Consumers for the Green Transition, commonly referred to as EmpCo, introduced by the European Union (EU). Enforced since March 2024 and applicable across all EU Member States by September 27th, 2026, this directive establishes stringent minimum requirements for combating greenwashing and social-washing.

Understanding the scope of EmpCo is critical for tourism businesses worldwide:

• The Target Market EU Principle: The directive protects every consumer present in the EU, regardless of their nationality or citizenship. If a travel company based outside the EU advertises its services to consumers within the EU, those communications fall under the directive's jurisdiction.
• Broad Definition of Sustainability: EmpCo's scope extends beyond ecological claims, and covers the "social characteristics" of products or traders' businesses, including claims around the fairness of working conditions, human rights, equal opportunities, gender equality, inclusion, and diversity.
• B2B Visibility Matters: While the primary objective is consumer protection, EmpCo encompasses all marketing activities that have the potential to affect EU consumers. Publicly visible communication materials, such as LinkedIn posts or online sustainability reports, fall under its purview even if intended primarily for B2B audiences.

These EU-level directives are implemented through national legal frameworks, such as Germany’s Act Against Unfair Competition (Gesetz gegen den unlauteren Wettbewerb), the Italian Consumer Code (Codice del Consumo), and the Dutch legislative act on Better Sustainability Information for Consumers (richtlijn betere duurzaamheidsinformatie voor consumenten). 

We may be tempted to ask, but why all these new rules? But it's important to remember that all businesses actually already operate within the legal frameworks that prohibit unfair and misleading claims.

It’s never been OK to advertise with false claims. EmpCo simply clarifies some of the specifics regarding sustainability communication. The core idea of EmpCo is nothing new. Our marketing must reflect our actual performance and not empty promises. Within the context of EmpCo, the focus is primarily on consumer protection. But it's also a matter of sensible business practices, as integrity in marketing should be a key part of operating a competitive, healthy, and responsible company.

The Risks of Non-Compliance and Greenhushing

Failing to comply with these standards introduces significant compliance risks. Businesses may face warning letters, complaints from consumer groups or competitors, and legal actions such as preliminary injunctions. Credible and effective sustainability communication is NOT just about avoiding punishment. It is, however, important to be aware of the consequences of non-compliance. Regardless of whether a company is intentionally employing greenwashing tactics, consumer protection agencies, government departments enforcing fair competition, and NGOs representing consumer interests can find, expose and in some cases indeed bring legal action against your claims.

The official EU-wide rule for EmpCo-related fines is up to 4% of a company’s annual turnover (or a fixed ceiling of €2 million) for violations. The enforcement mechanisms may differ according to each national framework, but it’s important to note that (1) there can be actual financial and legal consequences for non-compliance, and (2) there definitely are reputational risks if we are not communicating in a credible way.

To avoid these risks, some businesses resort to Greenhushing - the practice of deliberately under-reporting or hiding sustainability efforts out of fear of being accused of greenwashing. However, this poses its own critical risks. A key aim of sustainability communication is stakeholder engagement. Silence can lead stakeholders to assume a company is failing its targets or actively hiding negative impacts, causing the business to lose traction with a growing demographic of conscious consumers.

Compliance and Credibility in Tourism Marketing

In the competitive landscape of tourism marketing, compliance should be considered a fundamental risk management strategy. Beyond financial penalties and legal sanctions, greenwashing is a reputational risk, as false claims (intentional or otherwise) can erode trust in your brand. As such, viewing compliance only as a way to avoid punishment misses the strategic advantage of genuine credibility. In a crowded market where "eco-" and “sustainable” are often used as generic buzzwords, transparency and verifiable claims serve as powerful differentiators. Destinations that back their promises with recognized certifications and verifiable data move beyond mere marketing to build a reputation for integrity. By prioritizing credibility over hype, tourism providers can secure a competitive edge through trust that cannot be easily replicated by competitors.

What Constitutes an Environmental Claim?

To communicate effectively, a business must first understand when it is making an "environmental claim." Under EmpCo, this term describes any business activity used for marketing or sales purposes that implies or suggests a positive, lower, or zero environmental impact, or any other socio-environmental benefit.

• Scope: Claims can describe a business entity, a product, a service, or even packaging.
• Exclusions: Highlighting practices implemented strictly to fulfill a regulatory requirement (e.g. mandatory disclosure) does not qualify as a promotional environmental claim.
• Beyond Text: Environmental claims are not limited to words like "eco-friendly." They encompass illustrations, images, graphic elements, and symbols. The use of the color green, nature motifs, or leaf symbols without accompanying factual context implies environmental benefits and is heavily regulated.

Moving from Generic to Concrete Claims

EmpCo classifies environmental claims as "generic" if they are not further specified or concretised. Broad, vague statements like "green," "climate-friendly," "conscious," "regenerative," or "empowering communities" lack specific evidence and are classified as green- or social-washing.

To transition from vague to concrete, a claim must clearly describe the specific nature of the benefits being created. For example, instead of merely stating "We are sustainable," a hotel should articulate, "We have reduced our property's water consumption by 20% through the installation of low-flow fixtures." This specifies the exact action and achievement, ensuring unambiguous communication.

What Counts as Permissible Evidence?

Whenever environmental and social claims are made, they must be accurate, clear, and substantiated. Trustworthy evidence must be logical, methodologically sound, and publicly accessible. Examples of permissible evidence include peer-reviewed scientific studies, audited organizational reports, and detailed internal data disclosures. Crucially, a source citation must always be provided directly alongside the claim.

Navigating Certification and Accreditation

A common question is whether a business must be formally certified to communicate its sustainability efforts. The answer is no; certification is not a strict legal prerequisite. However, if a certification label is used as proof of an environmental claim, that certification system must meet rigorous transparency and independence requirements.

It's important to understand these two terms:

• Certification: ​​A voluntary third-party audit process confirming that a product, service, or system meets defined requirements. It provides solid, publicly accessible proof of a claim.
• Accreditation: A validation process confirming that a certification body is competent to perform audits.

So in order for a company that is certified to make an environmental claim, is it necessary that the certification provider is accredited? Not necessarily. An official accreditation will be a helpful way to confirm that the provider is transparent and independent. However, accreditation is not a mandatory legal requirement under EmpCo for making a valid claim.

Requirements for a Permissible Certification System

1. Independently Audited: The system must involve an independent third-party verification by an auditor that is independent of both the scheme owner and the user (or the company receiving the label).
2. Transparency: All requirements, terms of use, and the methodology behind the label must be publicly available. A consumer should be able to look up exactly what a label means and how a product or a company earned it.
3. No Proprietary Labels: Proprietary "trust marks" or in-house labels that just look like certification (e.g. a logo or a badge created by your own marketing department) are prohibited. If you use a visual cue that looks like a "seal of approval," the consumer will expect it to be verified by an outside party. If it isn't, it is not permissible.
4. Openness & Non-Discrimination: The scheme must be open to all who are willing and able to meet its requirements. If a label is "exclusive" to one company or a closed group of partners, it is generally considered a proprietary label and thus not permissible.
5. Clear Standards & Regular Monitoring: The scheme must include a formal procedure for dealing with non-compliance. This includes regular monitoring and the power to withdraw the label if a company fails to maintain the standards.
6. Expert & Stakeholder Consultation: The requirements of the scheme cannot be drafted in a vacuum. They must be developed in consultation with relevant experts and stakeholders (e.g. NGOs, scientists, and industry bodies) to ensure the criteria are scientifically robust.

Common Misleading Tactics to Avoid

Even well-intentioned businesses can inadvertently engage in greenwashing by misrepresenting their environmental impact. Understanding prohibited marketing practices is vital for maintaining credibility.

• Cherrypicking: This tactic promotes highly visible, trendy "quick wins" while ignoring significant negative impacts in other areas. For example, a restaurant campaign celebrating the removal of plastic straws is misleading if the business continues to rely heavily on other single-use plastics or fails to address high-footprint menu items like imported beef.
• Omission and Hidden Compromises: Highlighting a single positive attribute while concealing trade-offs is deceptive. A brand cannot claim to be "carbon neutral" if the offset investments only cover its corporate office while ignoring the supply chain. Similarly, advertising a product as having "100% recyclable" packaging is misleading if it solely applies to the box, and ignores the non-recyclable nature of the actual product inside.
• Irrelevant or Self-Evident Details: Advertising facts that are true but meaningless or legally required for all competitors is greenwashing. For instance, promoting a glass water bottle as "BPA-Free" is an irrelevant claim, as glass naturally never contains BPA. Likewise, advertising a digital booking app as "accessible" when it merely complies with the mandatory European Accessibility Act (EAA) falsely positions standard legal compliance as a proactive sustainability feature.

Communicating Meaningful Benefits

To ensure claims communicate meaningful benefits, businesses must strictly avoid empty superlatives (e.g., "the greenest choice") and hidden trade-offs. Any comparative claims must be objective, transparent, and based on sound methodology. For example, rather than claiming to be the "most sustainable hotel," a property should state its performance "compared to the national average," providing the baseline data, citing publicly accessible sources, and acknowledging areas where improvement is still required.

The Legal Requirements for Future Pledges

In the realm of climate action, future-oriented promises such as "Net Zero by 2050" are incredibly common. However, ambition without a structured plan is a form of greenwashing. Under EmpCo, claims relating to future performance are considered misleading and non-permissible unless backed by a realistic, measurable, and publicly accessible implementation plan.

A pledge does not equal a plan. Simply signing an initiative (e.g. Glasgow Declaration on Climate Action in Tourism) is an excellent first step, but marketing that signature as an environmental achievement without a concrete roadmap violates consumer protection laws.

A permissible implementation plan must include:

• Measurable targets with specified deadlines.
• Clear budgeting and assigned corporate responsibilities.
• A detailed, step-by-step implementation roadmap.
• Monitoring and auditing by an external third party.
• Progress and outcomes that are published and easily accessible to the public (e.g. in an annual sustainability report).

Setting Measurable Goals and Key Performance Indicators (KPIs) 

A goal to "reduce emissions by 50% by 2050" is flawed if it lacks interim targets, a defined baseline year, and clarity on the specific emissions (Scope 1, 2, or 3) being addressed. Simply stating your intent to achieve a certain amount of reduction is greenwashing because: 

• A distant target date as a distraction: Without concrete interim targets, it remains unclear what measures are being taken today.
• Lack of accountability: The goal is difficult to verify without objective short-term commitments and creates little genuine accountability. 
• Incomplete goal-setting: The target lacks transparency (50% of what? Compared to which baseline?) and is therefore not meaningful.

Consider a more well-structured example for a hotel setting greenhouse gas reduction goals. Instead of a vague promise, the goal should read, for example:

"Reduce absolute operational greenhouse gas emissions (Scope 1 and 2) by 55% by December 31st, 2029, against a verified 2025 baseline, through onsite renewable energy transition and electrification of heating and ventilation systems."

To objectively report progress and continuous improvement over time, tangible KPIs must be established. For this hotel, KPIs might include, for example:

• Renewable Energy Mix (%): The percentage of total building electricity supplied by onsite solar systems.
• Asset Electrification Ratio (#): The number of fossil-fuel-powered boilers decommissioned and replaced with high-efficiency electric systems.

These data points can be tracked via utility invoices and equipment logs, forming the objective, verifiable foundation required for credible, future-oriented sustainability communication.

It is easy to view evolving legal standards as a hurdle, but at its heart, credible sustainability communication is about clarity, connection, and accountability. So consider these regulatory frameworks as a reminder to focus on real, tangible action, and to elevate your brand by walking the talk on sustainability commitments. EmpCo gives tourism players a clear framework to replace vague, generic promises with concrete facts and verifiable data on progress. By stepping away from generic buzzwords and anchoring your marketing in trustworthy evidence, clear implementation plans, and real operational achievements, you are strengthening the core of what tourism marketing is really about: engaging your audience in stories of what makes your business or destination truly unique. 

So here are your concrete next steps to turning integrity into your competitive advantage: Use the lessons shared in this guide and begin taking practical steps across your key marketing channels. Focus on where your business is making a tangible difference and ensure marketing reflects your actual performance. And importantly, avoid the urge to rely on greenhushing by confidently and honestly telling your unique story. Remember, your effort in credible sustainability communication is not just about meeting compliance requirements, but also about reaching conscious travellers seeking experiences that reflect their values. 

This How-To Guide was created by the teams at TrainingAid and reCET, based on the two organisations’ collaborative work throughout 2025 and 2026 focused on supporting tourism stakeholders—from national and regional destination organisations, to industry networks and associations, to accommodation, hospitality and service businesses—go beyond compliance and turn EmpCo into opportunities for credible communication and effective engagement.