The EU’s new greenwashing rules apply from 27 September 2026, and they change what hotels, airlines, tour operators and booking platforms are allowed to say about the environment. In July we covered what the crackdown means for how you book. That date has now arrived — and this is the part that got lost in the summer coverage.

There’s a third ban in this law that almost nobody has written about, and it’s the one most likely to change what you actually see when you’re comparing hotels. There’s a mix-up about which law this even is that has made its way into a lot of otherwise solid reporting. And there’s an uncomfortable question underneath all of it: who is going to enforce this, and what happens if the answer is nobody in particular?

If you run a travel business rather than book one, skip to the compliance checklist for travel brands further down.

What the EU greenwashing rules ban from 27 September 2026

The law is the Empowering Consumers for the Green Transition Directive — ECGT, formally Directive (EU) 2024/825. It adds a set of green marketing practices to the EU’s blacklist of unfair commercial practices, which means they’re prohibited outright: no case-by-case test of whether consumers were actually misled.

Three prohibitions do most of the work in travel:

  • Generic environmental claims — “eco-friendly”, “green”, “climate-friendly” used on their own, without demonstrated performance behind them.
  • “Carbon neutral” claims based on offsetting — covering “CO2 neutral”, “climate neutral” and “climate positive” too.
  • Sustainability labels that aren’t independently grounded — the one nobody covered, and the subject of the next section.

The third ban: eco-badges themselves

The two prohibitions everyone covered were about words. The third one is about badges, and for anyone who books through a big platform, it may matter more.

The directive prohibits displaying a sustainability label that isn’t based on a certification scheme or established by public authorities.

Read that again with a booking site in mind. The green leaf icons, the “eco-certified” ribbons, the little award graphics that appear next to some properties and not others — under these rules, those need to trace back to a real certification scheme or a public authority. A badge a company invented for itself, awarded to properties on the basis of a form they filled in, is exactly the thing being banned.

This is the quiet, structural change in the law. Generic words were always easy for a traveler to discount — most of us learned to skim past “eco-friendly” years ago. A badge is different. A badge looks like verification. It sits in the search results next to the price and the review score, in the same visual language as things that have actually been checked. That’s what made self-awarded badges effective, and it’s why removing the unverified ones is the provision most likely to change how a results page reads.

Watch for it over the next few weeks. Some badges will disappear. Some will stay and gain a link explaining which certification sits behind them. That link — or its absence — is now your single most useful signal on a listings page.

Is this the Green Claims Directive? No — and the difference matters

Here’s something to arm yourself with, because you’ll see it repeated everywhere this week. There are two EU laws with nearly identical names, and most travel coverage has merged them into one:

  • The Green Claims Directive was a proposal that would have required companies to have environmental claims independently verified before they used them. The Commission announced its withdrawal in 2025. It is not law. It is not what takes effect this month.
  • The Empowering Consumers for the Green Transition Directive — ECGT, Directive (EU) 2024/825 — is the real one, and the one applying from 27 September.

Why does this matter to you as a traveler rather than a lawyer? Because the withdrawn proposal was the piece that would have forced companies to prove claims to an outside body first. Without it, ECGT bans certain claims outright but doesn’t create any pre-approval system. Nobody is checking a hotel’s green claims before they go live on the website.

So if you read that European companies now have to get their environmental claims verified before publishing them — that’s the withdrawn law, and it isn’t happening. What’s actually happening is narrower: a specific list of practices is prohibited, and someone has to notice and act when a company breaks the rules. Which raises the obvious question.

Who enforces the EU green claims rules?

ECGT is a directive, not a regulation. That means each EU country writes it into its own national law and enforces it through its own consumer protection authority. Countries were supposed to have transposed it by March 2026 for it to apply from 27 September.

In practice, this means enforcement will be patchy, at least at first. Some national regulators have been genuinely aggressive on greenwashing — the Netherlands and France among them, and it’s no accident that the landmark airline cases came out of German and Dutch courts. Others have small consumer protection teams and long queues of complaints.

Coordinated EU consumer enforcement can, in the most serious cases, reach fines of up to 4% of annual turnover in the countries involved. That figure gets quoted a lot. It’s a ceiling for major coordinated actions, not a standard penalty, and the realistic near-term outcome for most companies that break these rules is a correction and an undertaking to stop — not a headline fine.

None of that makes the law toothless. It does mean the first months will be about which regulator moves first, and against whom. A big airline’s offset product would be the obvious opening case.

What travel brands will say instead

The honest prediction is that green claims won’t disappear. They’ll get more specific — and that’s both the point of the law and its next problem.

“Carbon neutral flight” is banned. “This route operated with 12% sustainable aviation fuel” is not. “Eco-friendly hotel” is banned. “Certified under [named scheme], audited 2025” is not.

That’s genuine progress: a specific claim can be checked, and a company can be held to it. But it moves the difficulty rather than removing it. Vague claims were easy to dismiss and hard to defend. Specific claims are persuasive and much harder for an ordinary traveler to evaluate. Is 12% SAF good? Compared to what? What does that certification actually audit?

And because the pre-verification law was withdrawn, a company can publish a precise-sounding figure that no independent body has examined. Precision is not the same as verification. That’s the distinction to carry into next year.

Your updated booking checklist

Part 1’s checklist still holds. These are the additions for the post-27-September world:

  • Click the badge. If a sustainability label doesn’t link to a named certification scheme or a public authority, treat it as decoration. Under the new rules it shouldn’t be there at all.
  • A number is not a verification. When a claim gets specific — a percentage, a target, a figure — check whether anyone outside the company has confirmed it. Look for the word “audited” and the name of who did it.
  • Watch what disappears. The most telling thing over the next month isn’t what companies say, it’s what they quietly delete. A brand that scrubs its offset language without replacing it with anything is telling you what that language was worth.
  • Offsets are still fine to buy. Neutrality isn’t fine to claim. If a checkout page still says your flight is carbon neutral in October, that’s not a gray area. It’s a listed prohibited practice.
  • Non-EU bookings benefit indirectly, not legally. Big chains standardize their marketing globally rather than running one version for Europe. Expect the vaguest claims to fade from booking pages worldwide — but you have no legal protection on a booking outside the EU, and shouldn’t assume the badge means the same thing.

The green claims compliance checklist for travel brands

If you run a hotel, guesthouse, tour company or booking platform selling to EU consumers, these rules bind you — and there is no small-business exemption. A twelve-room guesthouse making an unsubstantiated “eco” claim is doing the prohibited thing exactly as a hotel group is.

Here is the whole compliance job on one page. Work down it once.

1 · The words

  • Search every channel for: eco, green, sustainab, carbon, neutral, climate, offset, plastic-free
  • Cut or rewrite every standalone claim — “eco-friendly”, “green”, “sustainable” — with nothing behind it
  • Cut every carbon neutral / climate neutral / climate positive claim that rests on offsets
  • Keep the offset product itself, if you have one — describing what it funds, not what it cancels
  • Replace cut claims with something specific and dated (“100% renewable electricity since 2024”)
  • State the comparator wherever you claim “lower” or “less” — lower than what?

2 · The badges

  • Retire every sustainability badge you awarded yourself
  • Check each remaining badge: scheme named, certificate current, audit year known
  • Make each badge one click from its scheme and certificate

3 · The places you forgot

  • Checkout and booking engine — the offset opt-in wording. The highest-risk screen you own
  • OTA listings, room and rate names, ad copy, meta descriptions, social bios, automated emails
  • Printed signage, brochures and PDFs still in circulation
  • Email tourism boards, awards and partners holding old copy — corrected wording attached

4 · So it stays fixed

  • File the evidence for every surviving claim: data, method, date, owner
  • Name someone responsible for green claims, and diarise a six-month review

If you only do one thing: cut anything you couldn’t prove in an email tomorrow. Removing an unprovable claim costs almost nothing. Defending one costs weeks.

This checklist is general information, not legal advice. The directive is implemented through national law that varies between member states — check anything consequential against the directive text or a qualified adviser.

EU greenwashing rules: common questions

Do the EU greenwashing rules ban carbon offsets?

No. Offsetting itself is not banned. What is banned is claiming a product is carbon neutral, climate neutral or climate positive on the basis of offsetting outside its value chain. A company can still sell you an offset; it cannot describe the resulting flight or stay as neutral.

When do the rules take effect?

27 September 2026, across all 27 EU member states. Member states were required to transpose the directive into national law by March 2026.

Do they apply to non-EU travel companies?

EU consumer protection law generally reaches traders who direct their activities at consumers in a member state. A UK, US or Asia-based operator marketing to EU travelers should assume it is in scope. As a traveler, though, you have no legal protection under these rules on a booking made outside the EU.

What are the penalties?

Coordinated EU consumer enforcement can reach fines of up to 4% of annual turnover in the member states concerned, but that is a ceiling for serious coordinated cases rather than a standard penalty. Corrections, undertakings and platform delistings are the more likely near-term outcomes.

Which eco-certifications still count?

Labels based on independent certification schemes with audited criteria, or schemes established by public authorities. In tourism that includes GSTC-accredited certifications, the EU Ecolabel, Green Key and various national programmes. Self-awarded badges do not qualify.

What we’re watching next

Three things over the next few months: which national regulator brings the first travel case, whether the big booking platforms retire or re-document their in-house eco-badges, and whether any member state missed the March transposition deadline and is therefore enforcing nothing at all.

We’ll report on all three as they land — and every date that matters is tracked on the Policy Calendar. The law changing is the easy part. Whether anything changes on the booking page is the story worth following.

Booking this autumn? Use the two-second version: click the badge, and if it doesn’t lead anywhere, it doesn’t mean anything.