Anti-Greenwashing Directive: What Travel Agencies Must Do Before 27 September 2026

If your website says "eco-friendly" — you have less than 90 days to prove it

On 27 September 2026, EU Directive 2024/825 — known as "Empowering Consumers for the Green Transition" — enters into force. From that day, any environmental claim on your agency's website, brochures, social media posts or email campaigns must be backed by verifiable evidence. Otherwise it becomes a prohibited commercial practice — with fines of up to 4% of annual turnover.

This is not a proposal. It is not under review. It is law, already transposed by Member States by 27 March 2026. And it directly affects travel agencies and tour operators who communicate sustainability to their clients.

The problem: according to the ASA's 2025 report, out of 362,000 digital ads from travel agents analysed, 67% of those containing environmental claims were found likely non-compliant with green communication rules. Two out of three agencies talking about sustainability are doing so in ways that, from 27 September, will be illegal.

What exactly Directive 2024/825 prohibits

The directive amends EU consumer protection and unfair commercial practices rules. The most relevant prohibitions for the travel sector are:

Generic environmental claims without proof. It is prohibited to use terms such as "ecological", "green", "eco-friendly", "environmentally friendly" or "sustainable" without demonstrating recognised, excellent environmental performance. "Our tour is sustainable" with no verifiable data? Unfair commercial practice.

"Carbon neutral" based on offsetting. This is the most discussed change. It is prohibited to claim that a product has a neutral, reduced or positive impact on emissions when the claim is based on offsetting emissions outside the product's value chain. Claims like "zero-impact travel", "carbon neutral flight" or "CO₂ offset tour" will only be admissible if the product's real life-cycle impact justifies them — not because external carbon credits were purchased.

Uncertified sustainability labels. Environmental labels not based on a recognised certification scheme or established by a public authority are prohibited. That self-created "eco-certified" badge on your brochure? It needs to go.

Unverifiable comparative claims. Phrases like "the greenest way to travel" or "less carbon than flying" require objective evidence and accessible methodology. The burden of proof sits with your agency.

Important: do not confuse this with the "Green Claims Directive"

A key clarification. Two different rules circulate and are easily confused:

Directive (EU) 2024/825 (Empowering Consumers) is approved, in force and mandatory from 27 September 2026. This is the one that concerns you today.

The Green Claims Directive proposal was a complementary rule that would have established prior verification procedures. The European Commission announced its withdrawal in June 2025, deeming it too burdensome. It is not in force.

The withdrawal of the Green Claims Directive does not ease the pressure: the substantive obligations on environmental claims live in Directive 2024/825, which applies. The notion that "there's no anti-greenwashing regulation anymore" is false.

The travel case: concrete examples of what changes for agencies

Here is how the directive impacts everyday communications of an agency or TO:

Case 1 — The "Sustainable Travel" page on your website. If you have a website section grouping tours under a "sustainable" or "eco-friendly" label, you must be able to demonstrate what makes each trip genuinely sustainable. Which certification? Which measurable environmental criteria? If the answer is "the hotel has biodegradable soap and doesn't wash towels daily" — that is insufficient.

Case 2 — The supplier who self-certifies as "green". Many agencies resell packages from TOs claiming "eco-lodge" or "sustainable resort". The Directive applies to whoever makes the claim to the consumer — that is you. If you promote a product as green in your marketing materials, verification responsibility is yours, not the supplier's.

Case 3 — The Instagram post "Zero impact travel". Your social team publishes a reel about an itinerary and adds "travel green with us" or "zero impact adventure". That phrase is an environmental claim subject to the directive. Without supporting data, it constitutes a prohibited commercial practice.

Case 4 — The brochure with an "eco-certified" badge. If the badge does not correspond to a recognised certification scheme (such as Travelife, Green Globe, EU Ecolabel), it must be removed immediately.

Case 5 — The newsletter "We offset your flights' emissions". Even if your agency purchases carbon credits for every flight booked, you can no longer communicate this as "neutral impact" or "carbon neutral". You can say "we purchased carbon credits for X tonnes of CO₂ through project Y, certified by Z" — specific, verifiable, not generic.

The penalties: what you actually risk

The directive is built into the penalty regime of consumer protection law. For widespread cross-border infringements, fines can reach at least 4% of annual turnover in the affected Member States, on top of measures such as campaign withdrawal or a ban on the practice.

The exact amount depends on national transposition. In the UK, the CMA and ASA enforce green claims. Across the EU, each member state's consumer protection authority is competent.

Beyond the financial penalty, reputational risk is immediate: from 27 September, any consumer, regulator or competitor can challenge an environmental claim and demand the evidence behind it. In a sector where trust is the primary asset, a public greenwashing accusation can be more damaging than the fine itself.

The ASA report: what real data tells us about agencies

The UK Advertising Standards Authority analysed 362,000 digital ads from leading UK travel agents between August 2024 and June 2025. The findings:

- Fewer than 1% of ads (319 out of 362,000) contained an environmental claim — signalling that most agencies avoid the topic entirely due to uncertainty about how to communicate correctly - Of that 1% who tried, 67% were assessed as likely non-compliant with green communication rules - Most common problematic claims: "greener way to travel", "less carbon than flying", "eco resort", "eco lodge", "carbon conscious" - Only 33% of claims were assessed as likely compliant

As the ETC/GDS-Movement report published in June 2026 emphasised: claims must be "clear, specific, evidence-based, and not misleading", applying across text, visuals, labels and branding.

Operational checklist: 10 actions before 27 September

Here is what to do concretely to become compliant:

1. Audit existing claims. Systematically review your website, brochures (including PDFs), social media posts, email marketing, newsletter templates, product descriptions. Search for any reference to sustainability, environment, ecology, carbon, green, zero impact.

2. Classify each claim by risk level. Generic claims without evidence ("eco-friendly", "sustainable", "green") = high risk, remove or transform into specific claims. Specific claims with evidence ("Travelife Level 2 certified") = low risk.

3. Remove unverifiable generic claims immediately. "Sustainable tours", "travel green", "eco-friendly" without certification backing: remove them today. Do not wait for September.

4. Remove carbon neutrality claims based on offsetting. If your offset programme is not based on a life-cycle analysis demonstrating actual reduced impact, the "carbon neutral" or "zero impact" claim must go.

5. Verify supplier certifications. For every supplier you communicate as "sustainable" or "green": which certification do they hold? Is it a recognised scheme? Is it still valid? Document everything.

6. Replace generic with specific. Instead of "eco-friendly hotel" → "EU Ecolabel certified hotel" or "hotel with solar installation covering 60% of energy needs". Instead of "sustainable tour" → "tour using exclusively local transport and community guides with regional licences".

7. Create an evidence register. For every environmental claim you maintain, document: the data source, the certification reference, the verification date, the internal responsible person. This register is your insurance in case of challenge.

8. Train the team (social media included). Anyone publishing content on behalf of the agency must know the new rules. An Instagram post with #ecofriendly about an uncertified resort is a violation. Create simple, shared internal guidelines.

9. Review contracts with TOs/suppliers. If you resell packages communicated as "sustainable" by the TO, ensure you have documentation supporting the claim. Insert contractual clauses requiring suppliers to guarantee the verifiability of environmental claims they authorise you to use.

10. Communicate what you actually do. The directive does not prohibit communicating sustainability — it prohibits doing so vaguely or without verification. If your agency takes concrete actions (supports local projects, chooses certified suppliers, reduces office plastic, offsets with specific documented projects), you can and should communicate it. But with precision, data and transparency.

What you CAN continue to communicate (and how to do it well)

The directive does not close the door on environmental communication — it opens it for those who do it properly. Here are claims that remain admissible:

Recognised certifications. "Green Globe certified hotel / Travelife / EU Ecolabel / Rainforest Alliance" → perfectly lawful. The certification itself is the evidence.

Specific and verifiable data. "This tour eliminates all internal flights — all transfers are by train and local bus" → specific, measurable, verifiable claim.

Documented concrete actions. "Each booking contributes €5 to reforestation project XYZ, Gold Standard certified, which planted 12,000 trees in region ABC in 2025" → specific claim with project, certification and result.

Commitments with timelines. "By 2027, 100% of our hotel suppliers will hold Travelife Level 2 certification or above" → future commitment with verifiable deadline. Caution: you must be able to demonstrate a concrete action plan to achieve it.

From regulatory risk to competitive advantage

Research published in Frontiers in Sustainability identifies five major forms of greenwashing in tourism: questionable eco-certification use, inadequate waste management, misleading carbon offsetting claims, unsustainable resource use at destinations, and masking socio-environmental harm under the "green" label.

Agencies that align early with the directive will gain a double advantage:

Immediate differentiation. When most competitors must remove or dilute their green claims to avoid penalties, those who invested in verifiable transparency will emerge as credible references for sustainability-conscious travellers — a steadily growing segment.

Consumer trust. 62% of European travellers state they consider sustainability when choosing travel. But most do not trust generic claims. An agency communicating with data, certifications and transparency builds credibility that the claim "we travel green" can never achieve.

The 27 September deadline is not a threat for those who act now. It is an opportunity to stand out in a market where credibility will become the primary selection criterion.

Useful resources

- Full text of Directive (EU) 2024/825 — primary source - ETC/GDS-Movement: Navigating Green Promises with Proof — operational guide for tourism - ASA Snapshot Report: Environmental Claims in Travel Agent Ads — real data on agencies - EU Transition Pathway for Tourism — compliance resources - ECTAA Manifesto 2024 — European trade association position