EmpCo explained: What the new EU greenwashing rules mean for DMCs and properties
New EU rules on sustainability claims have now come into force, and they apply to anyone marketing to EU consumers, wherever their business is based. Read on to find out what the Empowering Consumers for the Green Transition Directive (EmpCo) covers, what a compliant claim looks like and why, for DMCs and properties doing genuine sustainability work, this is an opportunity rather than a threat.
Sustainability has become a key part of how inbound tour operators, DMCs and properties present themselves to the trade. Tour operators want to know how their local partners look after people and places, and many of you are doing excellent work. Until now, though, there has been little to stop vague or exaggerated claims sitting alongside the genuine ones.
EmpCo changes that. In our recent webinar, Emily (who is also a Travelife coach and auditor) walked our DMC and property partners through the new rules. Below, we summarise the key points and the practical steps you can take now.
What is EmpCo?
EmpCo is EU law and has applied since Sun 27 Sep 2026. Its core purpose is to protect consumers from misleading environmental claims and greenwashing.
Importantly, it applies whenever you are marketing or selling to EU consumers, regardless of where your business is based. That includes The Adventure Connection and all of our DMC and property clients worldwide. We see this as a positive change. Greenwashing is not good for anyone, and EmpCo gives genuine sustainability work the credibility it deserves.
What does it cover?
All B2C communications, including websites, emails, brochures and social media posts. This means anything still published, so older content may need checking as well as anything new.
Images and names, not just written text. A property called "XYZ Eco-Lodge" is itself a sustainability claim - what makes it ‘eco’?
Financial and legal penalties for non-compliance, imposed by national authorities in each EU country. Fines can reach 4% of annual turnover, although the details will vary from country to country.
EmpCo is not just for the travel industry. It applies across all sectors, so everyone in tourism is navigating what it means for us in practice.
What makes a sustainability claim compliant?
Any claim you make about sustainability must be:
Specific and transparent
Substantiated with data or evidence
Verified by a third party, where relevant
In addition, future commitments must be backed up with specific targets and an explanation of how you plan to get there, with regular progress reporting.
Sustainability labels and badges must come from compliant certification schemes or EU public authorities.
And the evidence behind every claim must be easily accessible, either right alongside the claim or via a direct link.
Here is how that looks in practice.
1. Be specific and transparent
Avoid: "Our lodge is eco-friendly", "We're a sustainable tour operator" or "We put the planet first".
Instead: "We've installed solar panels and use a water butt to collect and reuse rainwater for watering the kitchen garden. Since we installed the solar panels in 2018, our fossil fuel energy usage has reduced by 47%. We still need to use a back-up diesel generator when there are power cuts during the rainy season."
Notice that the better example is honest about what still needs work. That honesty makes the claim more credible, not less.
2. Back it up with evidence
Avoid: "We support local communities" or "We're carbon neutral". Claims of carbon neutrality are a particular red flag - claiming carbon neutrality because of offsets is now banned in the EU.
Instead: "97% of our staff are from the local town and its surroundings" or "From 2024 to 2025, we reduced the carbon emissions on our trips by 9%. This was primarily thanks to removing internal flights and replacing them with overland transfers. Our carbon measurements are done by independent consultancy XYZ."ec
3. Get it verified
Avoid: "We're leaders in sustainability."
Instead: "In 2023, we achieved Travelife Partner status and as of 2025, we are Travelife Certified."
4. Give future commitments a plan
Avoid: "We aim to halve our carbon emissions by 2030."
Instead: "We are striving to reduce our business' carbon emissions by 50% by 2030, based on our baseline measurement from 2019. To achieve this, we plan to switch the office to a renewable energy tariff (estimated reduction 10%), replace 40% of our vehicle fleet with EVs (estimated reduction 25%) and support our key accommodation partners with installing solar (estimated reduction 15%). These objectives have been independently verified for feasibility by our carbon accountants XYZ."
5. Only use recognised labels and badges
Self-made or generic "eco-friendly" style badges are not allowed. Labels must come from compliant certification schemes, such as Travelife or Green Globe - and of course used only if you are certified by them.
6. Choose images that match the claim
Generic images of forests, leaves, green landscapes and so forth, unrelated to your actual claim, should be avoided. Instead use a photo showing the specific sustainability claim that you are referring to. For example, a photo of the solar panels on your property when talking about reducing fossil fuel energy usage, or a photo of the large water tanks that you have in your safari vehicles to reduce single-use plastic bottles when discussing plastic waste reduction.
What it means for DMCs and properties
Supply chain responsibility: legal responsibility lies with the "trader", usually the tour operator. Tour operators are liable for claims made anywhere in their supply chain, so they will be asking you to comply.
B2C communications: even if you only work B2B, any information you pass to tour operators who then use it in their consumer marketing must be compliant.
You don't need to be perfect: your claims just need to be truthful. Be specific, be transparent, keep proof accessible and rely on accredited certifications.
Growing demand for certification: tour operators will likely favour DMCs and properties with verified third-party certifications, such as Travelife, because it streamlines their due diligence.
Don't go quiet: avoid greenhushing
Greenhushing means going quiet about your sustainability work for fear of getting it wrong. It is an understandable reaction, but it is the wrong move.
Tour operators want and need to see your sustainability work, both because the market expects it and because of the regulatory context. If they can't find the information, they may not consider working with you. Specific, evidence-based claims make it easy for tour operators to choose you, promote you and stay compliant. If you go quiet or resist the change, you risk getting left behind.
Keep sharing the amazing work you do. Just make it specific, transparent and evidenced.
A commercial opportunity
Compliance can become a commercial advantage when you showcase genuine, specific impacts. Imagine another DMC says "We support a local school" when it simply gives a hamper at Christmas and posts about it on social media. If you make regular donations, built the school's science lab and have a long-standing relationship with the school, EmpCo gives you the chance to say so in a way that stands out.
It also creates a level playing field. Businesses doing genuine work get the credit for it, and tour operators can trust what they share with their customers.
Five practical steps to get ready
Brief your wider team, particularly marketing staff and anyone who provides sustainability information to tour operators.
Review your existing marketing materials: your website, presentations, information shared with tour operators, social media, newsletters and so on.
Gather supporting data and proof for all active claims.
Complete our Sustainability Questionnaire if you haven't already (please get in touch to be sent the link).
Consider accredited third-party certification, such as Travelife, if you are not already certified.
If you need help with this we're happy to give general advice to our clients free of charge. If you would like us to assess your website we can do this too for a small charge.
Any questions, please contact Emily at emily@theadventureconnection.com
Please note: this article is for general guidance only and is not legal advice.
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