Executive SummaryExecutiveSummary The OPPORTUNITY BEHIND THE RISK While the Directive serves to reduce greenwashing,THE OPPORTUNITY BEHIND THE RISK A shift from narrative to evidence TheEU Empowering Consumers for the GreenA SHIFT FROM NARRATIVE TO EVIDENCE Transition Directive(EU) 2024/825 (commonlyreferred to as EmpCo) introduces a fundamentalshift in how environmental claims can be made andcommunicated. it also raises the bar for meaningful communication. Organisations that invest in evidence andverification can move beyond generic claims andcommunicate with clarity and confidence. ThisThe EU Empowering Consumers for the GreenWhile the Directive serves to reduce greenwashing,Transition Directive (EU) 2024/825 (commonlyit also raises the bar for meaningful communication.referred to as EmpCo) introduces a fundamentalshift in how environmental claims can be made andOrganisations that invest in evidence andcommunicated.verification can move beyond generic claims and builds stronger relationships with visitors, clients,and partners, and supports more resilient long termcommunicate with clarity and confidence. Thisbuilds stronger relationships with visitors, clients,and partners, and supports more resilient long term sustainability claims used in marketing, branding,bidding, and other communications will be subjectto significantly increased legal scrutiny. Claims mustbe clear, specific, substantiated, and non-misleading, supported by verifiable evidence. Thisapplies not only to written statements, but also tolabels, visuals and any communication that mayimply environmental benefit. This shift creates a new opportunity. Organisationsgrowth. At the same time, those that choose not tocommunicate risk falling into greenhushing. This israrely a strategy. It is often a signal that systems,evidence, or internal alignment are not yet in place. The opportunity is not to say less, but to say better. From 27 September 2026, consumer-facingsustainability claims used in marketing, brandingbidding, and other communications will be subjectgrowth.to significantly increased legal scrutiny. Claims mustbe clear, specific, substantiated, and non-misleading, supported by verifable evidence. ThisAt the same time, those that choose not tocommunicate risk falling into greenhushing. This isapplies not only to written statements, but also torarely a strategy. It is often a signal that systems,labels, visuals and any communication that mayevidence, or internal alignment are not yet in place.imply environmental benefit. that can demonstrate credible performance will bebetter positioned to build trust, differentiate theiroffer, and strengthen their market position. For destinations, tourism businesses, and eventthat can demonstrate credible performance will bebetter positioned to build trust, differentiate theiroffer, and strengthen their market position. strategic asset. It requires evidence, traceability, andalignment across marketing, operations, and data,but it also enables more confident, compelling, andcompetitive storytelling.strategic asset. It requires evidence, traceability, andalignment across marketing, operations, and data,but it also enables more confident, compelling, andcompetitive storytelling What changes in practice Generic claims such as “sustainable” or “eco-WHAT CHANGES IN PRACTICE A common legal framework While the Directive creates a common legalA COMMON LEGAL FRAMEWORK friendly” are high-risk unless clearly substantiated Climate claims such as “net zero” or “carbonneutral” require clear scope, evidence, and viableplans Evidence must exist before claims are made and beavailable if challenged Visual and implied claims may be misleading ifunsupported by evidence Claims without independent verification carry nowcarry legal and reputational risk, thoughcertification is not a requirement · Generic claims such as "sustainable" or"eco-friendly" are high-risk unless clearly substantiated· Climate claims such as "net zero" or "carbonneutral" require clear scope, evidence, and viable: Evidence must exist before claims are made and beavailable if challenged. Visual and implied claims may be misleading ifunsupported by evidence• Claims without independent verification carry nowcarry legal and reputational risk, thoughcertificationis not a reguirement framework across the EU, implementation is alreadydiverging. Early national transposition across the EUindicates that enforcement approaches, andtherefore risk, will vary across markets. While the Directive creates a common legalframework across the EU, implementation is alreadydiverging. Early national transposition across the EUindicates that enforcement approaches, andtherefore risk, will vary across markets. significantly raises the standard for credibility, whichmake the pursuit of certification a wise choice, as, inpractice, organisations will increasingly needindependently verifiable evidence to support theirclaims. significantly raises the standard f