The Word ‘Sustainable’ Is Now Under Audit

A few months ago, while reviewing the commercial copy for an accommodation property, we came across a phrase that no one remembered approving: “A sustainable experience in complete connection with nature.” It sounded pleasant, took up little space and had been circulating on the website for years without prompting any questions. When I asked us to define exactly what it meant, the answers mentioned efficient lighting, the partial elimination of plastics, purchasing some local products and towel reuse. All were sensible initiatives. None, individually or collectively, explained such a categorical claim.

That episode sums up a widespread habit in Hospitality. We have used words such as sustainable, green, eco-friendly or responsible as narrative shortcuts. Instead of describing a specific action, we turned them into a brand atmosphere. A few leaves in the photograph, a refillable dispenser and a friendly phrase about the planet were enough to build an environmental identity. The sector learned to communicate intent before having a sound architecture of evidence in place, and intent, however noble, does not prove results.

As of 16 September 2026, eleven days remain until a significant change. On 27 September 2026, provisions arising from Directive (EU) 2024/825, adopted on 28 February 2024, will begin to apply. Member States were required to adopt and publish their transposition measures by 27 March 2026. The Directive amends the European framework on unfair commercial practices and consumer rights, strengthening protection against misleading environmental claims. Its specific implementation, inspection powers and penalty regime must be reviewed in the legislation of each Member State, but the purpose of the European obligation is unequivocal.

The most dangerous mistake would be to interpret this date as a minor website review task. Hotel greenwashing can no longer be regarded solely as a matter of reputation or ethical sensitivity. It now sits squarely within the realm of commercial compliance. It affects Marketing, Sales, Operations, Procurement, Maintenance, Food and Beverage, Revenue, Quality, legal counsel and anyone communicating an environmental benefit to consumers in connection with a stay, room, event, menu or ancillary service.

My proposal is that we stop managing these expressions as advertising creativity and start governing them as regulated commercial claims. Every environmental promise should have a scope, method, evidence, owner and review date. If the hotel cannot explain what it is claiming, which part of the experience it relates to, over what period and with what proof, the statement is not ready for publication. It may be inspiring, but it may also be a liability waiting for someone to ask the right question.

Green is no longer a marketing adjective

Directive (EU) 2024/825 has one uncomfortable virtue for those of us who have lived with overly elastic environmental communication: it requires us to distinguish between specific action and the overall image we project. A hotel may be reducing consumption, improving procurement and eliminating waste without being entitled to present itself generically as environmentally friendly. The operational effort exists, but the breadth of the claim may exceed the breadth of the evidence.

The Directive applies to commercial practices aimed at consumers. A hotel stay and its associated services fall within that scope. Product names, packages, room categories, audiovisual messages, symbols and graphic representations may also fall within it when they suggest an environmental benefit. A corporate report with no commercial purpose may be treated differently, but it ceases to be a neutral document when it is incorporated into the persuasion process, used to justify a rate or presented as a reason to book.

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It is worth recognising the main risk areas, because not all green claims fail in the same way:

• Generic environmental claims lose their former comfort. Expressions such as “green hotel”, “sustainable accommodation”, “eco-friendly”, “environmentally friendly” or “climate friendly” are subject to a particularly demanding threshold. Their use requires recognised, excellent environmental performance that is relevant to what is being claimed. Adding a green leaf next to the phrase does not improve the evidence; it merely ensures that the leaf becomes part of the problem too.
• A partial initiative cannot represent the entire hotel. Presenting the whole property as sustainable because it has removed plastic bottles from some rooms or installed efficient lighting in public areas creates a generalisation that is difficult to defend. The Directive specifically targets claims relating to the whole where the benefit applies only to one aspect, activity or specific category.
• Future promises require far more than enthusiasm. Claiming that a hotel will be carbon neutral, zero waste or climate positive by 2030 requires clear, public and verifiable commitments and targets. It also requires a detailed, realistic implementation plan, measurable milestones, timelines, allocated resources and periodic verification by an independent expert third party whose conclusions are available to consumers. A target written in an annual presentation is not equivalent to a plan.
• Offsets do not automatically make a stay neutral. It will be prohibited to claim that a product or service has a neutral, reduced, offset or positive emissions impact when that presentation is based on the purchase of external credits. A hotel may fund climate projects and explain that contribution accurately, but it should not present it to consumers as though it had eliminated the actual emissions of the booked service.
• Labels invented by the organisation itself are no longer an innocent resource. A sustainability label must have been established by a public authority or be based on a certification scheme that meets the required conditions. A logo designed in-house, even if it is elegant and took three meetings to decide the exact shade of green, does not thereby become a certification.
• Mandatory compliance cannot be presented as an exclusive advantage. Where a practice is required by law for the entire relevant category, advertising it as a differentiating environmental benefit may be misleading. Compliance with the law is essential; turning that common compliance into a competitive medal creates another problem.

There is an important nuance. A specific claim that is clearly explained in the same medium may cease to be considered generic. “Sustainable” is not corrected by placing a hidden footer link leading to a seventy-page report. The specification must appear clearly and prominently next to the claim or within the same commercial interface. If the space in an advertisement, OTA listing or social creative does not allow us to reasonably explain what we mean, perhaps that claim should not appear there.

This changes how we write hotel marketing. “Eco-friendly room” is a broad and risky designation. “Room equipped from 2025 with taps with a verified maximum flow rate of ‘data’ litres per minute” defines the subject more clearly, although it must still be true, relevant and substantiated. “Sustainable breakfast” explains almost nothing. “‘Percentage’ of our annual spend on fruit and vegetables comes from suppliers located within ‘defined distance or territory’, measured between ‘dates’” describes a verifiable reality, provided proximity and environmental benefit are not automatically conflated.

I have learned to distrust percentages that arrive without a surname. A 30% reduction in water consumption may be an excellent result or an empty figure. I need to know the baseline period, scope, activity unit and method. Are we talking about total consumption, per stay, per occupied room or per square metre? Does it include pools, laundry and gardens? Did the comparison year have the same occupancy? If that information changes how the figure is interpreted, it is part of the claim, even if it is aesthetically less appealing.

Precision does not impoverish communication. It makes it more credible. Guests do not need to attend an environmental engineering class in order to book, but they do deserve to understand what benefit is being presented to them. The hotel guest experience begins before arrival and rests on expectations. As I have argued when analysing the expectations guests bring from outside, a broad promise raises the bar against which the entire stay will be judged.

We must also review visual elements. A photograph of vegetation does not in itself constitute a generic claim, but when combined with text, labels, water drops, leaves, planets or environmental expressions, it may create an overall commercial impression. Package names such as “Green Getaway”, “Eco Stay” or “Carbon Neutral Meeting” are not protected simply because they function as product names. If the average consumer interprets them as communicating an environmental benefit, they must pass the same test.

Certifications deserve a cautious explanation because simplified lists of supposedly valid labels are beginning to circulate. The Directive does not create a blanket authorisation for any label issued by a third party. A private label must be supported by a certification scheme with defined and accessible requirements, verification by a competent third party and objective compliance monitoring. In addition, the scheme owner and the verification entity must maintain genuine independence, including legal separation.

Labels established by public authorities may continue to be used subject to their conditions. In the accommodation sector, the European Union Ecolabel is a particularly relevant reference when it has been awarded for the relevant service. Officially recognised regional or national Type I ecolabelling schemes may also demonstrate excellent environmental performance within their scope. A public environmental management scheme such as EMAS may add credibility and allow use of its label in accordance with its rules, but no label should be interpreted as permission to make every imaginable claim.

The right question, therefore, is not “do we have a certification?”, but “what exactly does it certify, for which service, under which version of the standard, until what date and with what right of use?”. I have seen hotels display expired labels, logos belonging to another company in the group and certifications for one building used to promote services outside the audited scope. The label was on the website; the actual coverage had fallen considerably short.

A valid certification does not make every phrase Marketing builds around it true either. It may authorise the use of a label and demonstrate certain requirements, but an additional claim about emissions, water, circularity or local impact needs its own correspondence with the evidence. The label is limited proof, not a semantic blank cheque.

Distribution adds another challenge. Hotel copy is replicated across OTAs, intermediaries, metasearch engines, agencies, destination profiles, bed banks, co-operative campaigns and operator materials. Some platforms summarise, translate or shorten descriptions. The result may retain the adjective “sustainable” while removing the explanation that made it specific. The audit cannot be limited to the master document; it must check what the consumer ultimately sees in every channel.

This connects with the need to conduct a reputation audit capable of identifying false promises before the guest does. In environmental matters, that discipline now incorporates a more visible legal dimension. A claim may be well written and still be vulnerable because the evidence has expired, the operation has changed or a distributor presents it out of context.

I would not advise basing a strategy on the hope that authorities will start with another company. Exposure does not arise only from an inspection. It may begin with a complaint from a consumer, an association, a competitor, a distribution platform or a public discrepancy between the campaign and the experience. The consequences may include withdrawal or correction of communications, administrative proceedings, penalties provided for under national law and reputational damage that rarely remains within the legal department.

This article provides a professional framework, but it does not replace the legal analysis applicable in each country and in each case. Hotels operating in several Member States should review their copy from a cross-border perspective. A commercial translation does not always retain the same legal meaning, and a word that is acceptable in one context may become a much broader environmental claim in another language.

Every environmental promise needs a licence to be published

In practice, the greatest risk does not lie in an isolated phrase. It appears when no one knows who has the authority to publish it, who retains the evidence and who must withdraw it when it ceases to be true. Marketing writes, Operations delivers, Procurement provides data, Maintenance measures consumption, Quality archives audits and Finance validates investments. Everyone participates, but no one owns the full responsibility. That diffuse allocation worked while sustainability was a corporate aspiration. It works much less well when every word must withstand scrutiny.

I propose creating an environmental publication licence. I do not mean an official permit or a new layer of bureaucracy, but an internal rule: no environmental claim is published unless it has a minimum approved file in place beforehand. The purpose is simple. Commercial creativity may improve the expression of a truth, but it must not manufacture the truth it needs to express.

The file should include, at a minimum, the following elements:

• Exact wording of the claim. It is not enough to record the general topic. “We reduce waste”, “zero waste” and “82% of operational waste was diverted from disposal in 2025” represent three different commercial commitments and require different evidence.
• Subject and scope. It must state whether the claim refers to the building, a room, a food and beverage service, an event, the laundry, a specific purchase or the organisation as a whole. It is also advisable to define which locations, legal entities and activities are excluded.
• Period and baseline. Every improvement requires a consistent point of comparison. The file must record the dates, the unit used, adjustments for occupancy or activity and any methodological changes that prevent direct comparison.
• Calculation method. The hotel must be able to explain where the figure comes from, which sources it uses, who performed the calculation and what its limitations are. A figure compiled from invoices may be valid, but it must be distinguished from direct measurement, an estimate or an industry model.
• Available evidence. Invoices, readings, certificates, audit reports, technical data sheets, contracts, weighings, waste records and guarantees of origin must be traceable. Evidence stored in the email account of someone who no longer works at the hotel is, operationally, evidence that will arrive too late.
• Owner of the operational truth. Every claim needs a person or function able to confirm that it remains true. Marketing may be the custodian of the wording, but the evidence owner may sit in Maintenance, Procurement, Quality, Food and Beverage or Finance.
• Authorised channels. An explanation that is adequate for an information page may be insufficient on an OTA, in an advertisement or in a social post. The file must state where the message may be used and which version applies to each format.
• Expiry and review date. Environmental claims should not live indefinitely. If they depend on annual data, supply contracts, certifications or purchasing percentages, they need a review date linked to those elements.
• Withdrawal conditions. The hotel must define which facts require the message to be suspended. Loss of a certification, a supplier change, refurbishment, interruption of measurement or a significant deviation may invalidate the claim before the routine review.

This register turns sustainability into a hotel management capability, rather than a collection of messages. It makes it possible to know what we can communicate, what needs correction and what is still at the project stage. It also prevents the same figure from appearing in different versions on the website, in a sales presentation and in a group proposal.

To prioritise the work, I use a claim traffic-light system. In red, I place generic terms without recognised excellent performance, neutrality claims based on offsets, proprietary labels, future promises without a verifiable plan and claims about the whole hotel supported by a partial action. In amber, I place specific data with an unclear baseline, incomplete methodology, outdated evidence or poorly explained scope. Only concrete, current, relevant, verifiable claims assigned to an accountable owner belong in green.

The green traffic light is not permanent. A claim approved today may turn amber if the electricity contract changes, the certificate expires or the service is modified. This fluidity is essential. In Hospitality, commercial truth ages at the pace of the operation, and the operation has the healthy habit of changing just after we print ten thousand brochures.

The review must cover more spaces than we usually include in a marketing audit. I would check the official website, booking engine, OTA listings, paid campaigns, pre-stay emails, social profiles, videos, Reservations talking points, Sales scripts, group proposals, menus, in-room signage, event materials, press packs, corporate presentations, package names and collaborations with content creators where the hotel has approved their messaging.

I would also review the photographs and labels used alongside the text. A leaf, a drop or a representation of the planet may seem decorative, but they acquire meaning when they accompany environmental expressions. The audit must analyse the overall impression received by the consumer, not merely the literal wording of each word.

At this point, a legitimate tension arises. The more precise we try to be, the harder it becomes to maintain simple, emotional communication. Yet precision does not mean overwhelming the guest with methodology. Hospitality work consists of building a complex evidence architecture internally and a clear explanation externally. Guests can receive an understandable phrase and, should they wish to explore further, have access to a page setting out scope, methodology, period and results.

Take the example “we have reduced our water consumption by 25%”. A responsible version could state that potable water consumption per occupied room decreased by a “verified percentage” between “base year” and “comparison year”, specifying the areas included. Expanded methodological information can then be provided. This construction allows consumers to understand the achievement without requiring them to review invoices or interpret meters.

With “zero waste”, we should be even more cautious. Few hotels can demonstrate that they generate no waste or that all of it avoids disposal. The message should be replaced with measured results: quantity generated per stay, percentage separated, verified destinations, reductions in specific waste streams or elimination of particular products. The ambition may remain, but it must be clearly distinguished from the result achieved.

Local purchasing presents another common trap. Proximity does not automatically mean lower environmental impact. A nearby supplier may make small, frequent deliveries, use formats with more packaging or generate higher spoilage. If the hotel communicates an environmental benefit, it needs to demonstrate it; if it wishes to highlight economic support for the local area, it should say exactly that. Social, cultural, economic and environmental benefits may coexist, but they are not interchangeable.

Something similar happens with on-request housekeeping, towel reuse or reduced amenities. These measures may reduce consumption, but they can also become cost savings passed on to the guest if they are poorly designed. If guests feel they are receiving less service while the hotel claims an environmental virtue, the initiative loses legitimacy. Sustainability should not be used to conceal operational cutbacks that weaken the hotel guest experience.

In my reviews, I try to apply an uncomfortable question: would we maintain this decision if we could not communicate it? If the answer is no, perhaps the primary objective was reputational. A robust environmental action usually provides value even without a campaign: it reduces consumption, avoids waste, improves resilience, protects resources, brings procurement into order or reduces risks. Communication amplifies that value; it should not be its only reason for existing.

Hotel revenue management is not exempt either. Some properties use environmental attributes to justify a higher rate, win companies with responsible travel policies or improve conversion among segments sensitive to these criteria. If generic claims disappear, part of that positioning may weaken. The answer is not to seek less scrutinised synonyms, but to build verifiable attributes that allow value to be defended more precisely.

A hotel with consistent measurements can turn its progress into a product. It can design meetings with measured consumption and waste, provide specific environmental information to corporate clients, develop food and beverage offerings with verifiable traceability or explain efficiency improvements that also enhance comfort. This connection between operations and commercial proposition adds more value than repeating a generic adjective.

Hotel profitability benefits when environmental priorities are subject to discipline. Measurement forces us to identify water leaks, overconsumption, waste, unnecessary purchasing and processes that add no value. Here I see a natural relationship with Lean thinking applied to the hotel industry: eliminating operational waste can simultaneously improve margin, service and impact, provided we do not confuse efficiency with impoverishing the guest experience.

We must also train the team that speaks with guests. There is no point publishing a carefully prepared environmental commitment if Reception, Reservations or Events cannot explain it without improvising. Training should cover what the hotel claims, what it does not claim, where to find further information and how to respond when someone asks about a certification, an offset or a figure.

It is advisable to avoid grandiloquent scripts. The team does not need to memorise a sustainability report. It needs brief, honest and consistent answers: “This certification covers the accommodation service until ‘date’”; “The figure refers to consumption per occupied room”; “We fund this project, but we do not present the stay as carbon neutral”; “We have not yet reached that target and we publish annual progress”. Acknowledging a limit inspires more trust than inventing certainty.

With 27 September 2026 approaching, I would apply an urgent plan divided into four moves:

• During the first 72 hours, I would freeze new environmental claims. No campaign, listing, package or material should incorporate green expressions until minimum validation has been completed. Continuing to publish while the audit is under way multiplies the versions and channels that will later need to be corrected.
• Over the following five days, I would inventory and classify existing messages. Priority should be given to generic claims, neutrality based on offsets, proprietary labels, environmental product names and future promises. I would not try to resolve every detail first; I would remove or suspend what presents an obvious risk.
• Before 27 September, I would correct the channels with the greatest commercial exposure. The website, booking engine, OTAs, active campaigns, conversion emails and group proposals should receive the initial focus. Distributors need explicit instructions and updated versions, not a generic message asking them to review sustainability.
• From the date of application onwards, I would implement a monthly review until the system is stabilised. It can then evolve into quarterly governance, provided major operational changes trigger extraordinary reviews. The ultimate aim is to prevent a claim from ever becoming orphaned again.

Governance requires a brief, cross-functional meeting, not a ceremonial committee. Marketing must provide the wording and channel; Operations, the actual ability to deliver; Finance or Procurement, the financial and contractual sources; Quality or Sustainability, the methodology and document control; and Legal Counsel, validation of the highest-risk expressions. Approval should be recorded together with the date and conditions of use.

One additional rule can save many problems: no supplier should write the hotel’s environmental promise on its own. Consultants, agencies and certification bodies may provide valuable information, but commercial responsibility does not disappear when creativity is outsourced. The hotel must understand the claim it publishes and retain sufficient evidence to defend it.

Nor would I consider old descriptions valid simply because they have worked for years. The rules apply to existing communications from 27 September 2026. There is no general amnesty for the historic brochure, the listing created in another season or the package that nobody remembers how to deactivate. Authorities may take proportionate, good-faith efforts into account, but that possibility should not become a compliance strategy.

This discipline may generate resistance. Someone will argue that other companies continue to use the same terms, that consumers understand the intention or that removing “sustainable” will weaken positioning. I have heard similar arguments during many commercial reviews. My response is usually that a competitive advantage based on a phrase we cannot substantiate was already more fragile than we thought.

The opportunity emerges when we replace rhetorical volume with evidence. A hotel that knows its consumption, explains its limitations, corrects its data and publishes verifiable progress builds trust that is difficult to replicate. Guests may not study every indicator, but they perceive the difference between an organisation that informs and one that merely poses. That difference also influences reputation, corporate relationships, talent attraction and the ability to defend price.

Hotel strategic planning should use this review to organise investment priorities. If the hotel wants to communicate environmental leadership in water, energy, waste or procurement, it will need to decide where it wants to demonstrate strong performance and where it can only report partial improvements. Trying to stand out in every dimension generates broad claims and scattered budgets. Choosing priorities allows resources to be concentrated, results to be measured and a more credible proposition to be built.

Ultimately, the Directive requires us to bring together two worlds that should never have been separated: what the hotel does and what the hotel says. This coherence benefits consumers, but it also protects the business from its own tendency to exaggerate good news. Sustainability will remain a strategic opportunity; it will simply no longer allow quite so much verbal decoration.

My first recommendation is very specific: search for the word “sustainable” alongside your hotel’s name today and review every result as though you were a sceptical guest. Then repeat the exercise with “eco”, “green”, “ecological”, “natural”, “responsible”, “neutral”, “zero waste” and “carbon”. Do not ask yet whether the phrase sounds good. Ask what it means, who can prove it and when it was last verified.

The second recommendation requires a little more courage: temporarily remove anything you cannot defend. Commercial silence for a few days costs less than a misleading promise for years. The hotel can continue working on sustainability without turning every action into advertising. Sometimes, the most responsible decision is to stop talking until there is something precise to say.

And the third looks beyond compliance. Use this regulation to build a culture in which important words need evidence before they travel. If we can apply that discipline to sustainability, we can extend it to accessibility, wellbeing, local product, quality, social impact and experience. A reliable hotel is not the one that promises the most. It is the one in which every promise has first found someone willing to stand behind it.