Selling sustainability to European guests? Watch your words.
Disclaimer: This article is for general information only and does not constitute legal advice. Whether EU, UK or other consumer-protection rules apply to your business depends on your circumstances. Consult a qualified lawyer before acting on anything in this article.
In September 2026, the UK Advertising Standards Authority (ASA) upheld complaints against several travel companies, including Thomas Cook, loveholidays and DialAFlight. Their ads used terms like "Eco Resort," "Eco Hotel" and "eco-conscious resort" without providing clear information or evidence to support them.
The rulings made two points that should worry any hotelier:
A word can count as an environmental claim even when it is part of a property's official name.
Advertisers stay fully responsible for the wording, whether it came from a the hotel itself, an operator or an automated ad tool.
The general principle in consumer law is that the rules follow the consumer, which is why where your guests sees your marketing may matter as much as where your lodge operates. As anti-greenwashing rules spread, your business may be affected in ways you didn't expect, wherever your property sits. The Booking.com case below offers another example of how that can happen.
The rules follow the guest
In March 2024, the Dutch consumer authority found Booking.com's "Travel Sustainable" badge programme, which labelled certain properties as sustainable, as possibly misleading. Instead of tweaking it for the Dutch market, Booking.com withdrew the programme altogether, saying it would develop a replacement built around third-party certification.
The properties that had participated lost whatever visibility the programme gave them, even though Booking.com, not the hotels themselves, had made the claims. The takeaway: your property can bear the consequences of a sustainability claim you never made.
The European Union's new Empowering Consumers Directive (EU 2024/825), whose rules have applied since 27 September 2026, further tightens the restrictions on environmental marketing claims:
General terms like "eco-friendly," "green" or "climate friendly" are banned unless backed by recognised environmental performance (the EU Ecolabel or ISO 14024 standards, for example) or by clear specifics on the same page.
Sustainability labels need independent third-party certification.
Claims of a neutral or positive climate impact through offsetting are banned.
Forward-looking targets such as net zero need detailed, measurable plans, verified by independent experts.
On paper, the directive has broad reach: it covers marketing directed at EU consumers, regardless of whether the business behind it is based inside or outside the Union. In practice, enforcement falls to national authorities, so the consequences will vary between member states. Whether a particular hotel or lodge falls within the directive’s scope is a question for a lawyer.
What's at stake
The most immediate risk is that your ads get pulled. Some anti-greenwashing regulations also carry financial penalties, though that hasn't happened yet in any of the cases I reviewed.
There's a commercial risk too, further down the chain. Under these rules, the party that can be fined or have its marketing withdrawn is the seller. For a package holiday, that's often a tour operator or travel agent, not the hotel. The exposure then flows back to the supplier through contracts, audits and the chance of being dropped from an agent's offering.
Hotels that cannot substantiate their claims may find themselves shut out of sustainability-focused procurement and lose visibility in platform filters and corporate travel programmes. The industry's shift towards third-party certification points in the same direction.
Where hospitality is vulnerable
Regulators have been looking at three places.
Names. A word in a property, package or room name can function as an environmental claim, regardless of what the marketing team intended. “Eco Resort” is the clearest recent example.
Words you didn't write. Resellers, booking platforms and ad tools write copy about your property. In the ASA ruling above, the advertiser couldn't even point to the tool that generated the phrase.
Badges. A platform label that implies a stay is sustainable can create its own exposure. Booking.com’s experience shows how quickly a platform-level decision can affect the properties associated with a programme.
None of this requires bad faith. A business can make a misleading environmental claim without intending to deceive anyone. Sometimes all it takes is a word, a name or an icon that promises more than the available evidence can support.
What an unsubstantiated claim looks like
To see how this plays out in practice, I reviewed the public websites, TripAdvisor pages and Booking.com listings of 15 South African lodges that use sustainability wording and market to European or British guests. I logged 72 sustainability claims.
This wasn’t a legal assessment, and I’m not judging whether any individual claim complies with the law. I looked at what each page actually says and whether the information provided allows a reader to check it.
Three patterns stood out:
Feel-good adjectives, with nothing behind them. Thirty-four claims used generic language like "eco-friendly," "light footprint" or "sustainability is central." None included evidence to substantiate the claim.
Numbers without baselines. Of 19 specific, quantified claims, 14 provided no baseline—the starting point against which a change is measured—no methodology or no independent verification. Not one of the 72 claims included data with both a named source and a baseline year.
Certifications are named, rarely explained. Of 12 claims involving certifications or badges, 10 gave only the name of the scheme. Just two specified what the certification covered and when it was issued.
One lodge says it runs entirely on solar power. The same page mentions a standby generator. Both statements could be true: the generator might be used only during outages. But the page doesn’t explain how the two fit together, leaving readers unable to tell whether “entirely” is accurate or an overstatement.
That ambiguity is typical of the problem I found. A claim may be true, but if the information on the website doesn’t allow a reader to verify it, the claim is difficult to assess from the outside.
Where to start
You don’t need to overhaul your marketing overnight. Start by finding out what you’re claiming, where those claims appear and what evidence supports them. The steps below are a starting point, not legal advice. If you run a small, owner-managed property, begin with the first three.
Search your names. Check every property, room, package and rate name for "eco," "green," "sustainable" and "natural." The EU directive defines an environmental claim broadly enough to include brand and product names.
Find out who is writing your copy. List every place where someone else's words describe you. Add a clause on environmental wording to your reseller contracts, and schedule regular reviews of the wording they publish.
Swap adjectives for facts. "Eco-friendly" tells a guest very little, and a regulator even less. Energy use cut by a stated percentage against a stated year, a named scheme, a named programme: those can be checked. If the fact doesn't exist yet, drop the claim rather than keep the adjective.
Treat badges as claims. A badge on a booking platform can shape a guest’s expectations just as much as your own website copy. Find out which badges appear on each platform, who awards them and what criteria they use. The EU directive bans displaying a sustainability label that isn't based on a certification scheme or set up by a public authority.
Spell out your certifications. Naming a scheme is a start, but it doesn’t tell a reader what was assessed. State the scheme, the scope of the certification—whether it covers one building or the entire business—and the date it was issued. Standards recognised by the Global Sustainable Tourism Council are a reasonable place to look. But recognition is not a guarantee: the council itself cautions that recognising a standard does not guarantee the reliability of the certification process behind it.
Keep a file for every claim. For each claim on your site, keep a record of its source, the baseline year for any figures, the methodology, any independent verification, who wrote the wording and when it was last reviewed. The test is straightforward: if someone challenges a line on your website, can you produce the evidence behind it?
And if you do have real sustainability work to talk about, don't retreat into silence. The answer to greenwashing risk isn’t to stop talking about sustainability. It’s to make fewer, more specific claims, and give readers something they can use to check them. That’s more credible than a long list of broad promises.
Want a second pair of eyes on your claims?
I’m a communications strategist with a journalism background. I help hospitality businesses explain what they do clearly and credibly. If you want to know what your website, booking listings and reseller copy actually claim, I can carry out the same kind of review I did for this article, tailored to your property. I’ll log the sustainability claims, flag the missing evidence and suggest plain-language rewrites you can use straight away. I’m not a lawyer, so I’ll also tell you when an issue needs legal advice.