In this practical guide for Green Globe Certified Members we’ll demonstrate how to communicate sustainability claims under European EmpCo legislation and explain how consumers will be better protected against unfair practices through better information.

Introduction: Why EmpCo Matters – Even Outside the EU

The EU Empowering Consumers Directive (EmpCo) represents one of the most significant shifts in sustainability communication globally. It fundamentally changes how environmental claims can be made to consumers. Even if your business is located outside the EU, EmpCo applies to any organisation marketing to EU consumers and from September 2026, companies targeting EU travellers must ensure that all sustainability-related messaging meets strict requirements for - accuracy, transparency, verifiability and consumer clarity.

The directive is designed to eliminate greenwashing by prohibiting vague and unsubstantiated environmental claims and ensuring only credible, evidence-based communication remains.

What EmpCo Changes for Senior Leadership

EmpCo is not simply a compliance issue, it is a strategic brand and risk management issue. At a leadership level, this means that sustainability communication moves from marketing language to → regulated consumer claims that must be supported by audit-ready evidence and clear substantiation. The burden of proof lies with the company, not regulators or consumers. Any guest-facing communication must be, truthful and verifiable, based on audited facts and limited to what has been independently verified.

Principles of EmpCo-Compliant Communication

To align with EmpCo, all sustainability communication should follow four core principles:

1. Specificity - Avoid general statements. Claims must clearly describe what aspect of sustainability is addressed and what scope (property, service, process).

2. Substantiation - All claims must be backed by data, documentation and measurable performance indicators.

3. Independent Verification - Claims must rely on recognised certification systems, third-party auditing (e.g. Green Globe Certification). Self-declared or unverified labels are not permitted.

4. Transparency - Consumers must be able to understand what the claim means and access supporting evidence if needed.

Practical Implications for Green Globe Members

Green Globe certification is structurally aligned with EmpCo principles because it provides public, clearly defined sustainability criteria by independent third-party verification. Green Globe Certification provides documented evidence supporting claims and transparent certification scope and validity.

However, certification alone is not sufficient, it must be communicated correctly with, importantly, responsibility for that communication with the member, not the certification body.

Do’s and Don’ts for C‑Suite and Marketing Leaders

✅ DO’s

Do communicate specific achievements - e.g. “100% renewable electricity used in operations since 2023”.

Do reference your Green Globe certification transparently, clearly state what is covered by certification.

Do ensure every claim can be verified with documentation.

Do align marketing teams with compliance/legal teams.

Do provide additional information access - e.g. “Learn more” links to certification criteria or reports.

Do use quantified data wherever possible.

Do update claims regularly as ongoing performance matters.

❌ DON’Ts

Don’t use vague terms such as “green”, “eco-friendly”, “sustainable hotel” (without proof).

Don’t exaggerate certification scope, only communicate what is actually certified.

Don’t rely on offsetting-only claims e.g. “carbon neutral” based only on offsets (this is restricted).

Don’t create your own sustainability labels or badges, only recognised certification systems are allowed.

Don’t make future claims without a credible plan, targets must be measurable and independently verifiable.

Don’t hide the evidence behind the claim - transparency is mandatory.

Example: From Non-Compliant to EmpCo-Compliant Messaging

❌ Before (Non-compliant)

“We are a sustainable and eco-friendly hotel committed to protecting the environment.” This fails as it’s vague and generic with no proof or scope and is not verifiable which is potentially misleading to consumers.

✅ After (EmpCo-aligned)

“Our hotel is certified by Green Globe, an internationally recognised sustainability certification programme. As part of this certification 92% of our energy consumption is sourced from renewable energy. Water consumption has been reduced by 28% since 2021, waste diversion from landfill exceeds 65% annually. These results are independently verified through annual third-party audits. Learn more about our certification criteria and performance here.”

This works as it’s specific and measurable, independently verified and linked to recognised certification that is transparent and auditable.

Strategic Takeaway for Executives

EmpCo marks a shift from sustainability as a brand story to sustainability as a regulated, evidence-based claim. For Green Globe Members, this is not a limitation, it is a competitive advantage as credible certification becomes more valuable, verified performance differentiates from competitors and trust becomes a measurable asset.

Green claims aren’t banned - they just need to be true and substantiated.

Final Recommendation

Executive teams should treat EmpCo as a cross-functional transformation project involving marketing, sustainability, legal/compliance and operations.

A structured internal review of all consumer-facing sustainability communication before September 2026 is essential.