News & insights / Insights / 16.09.26

How to Make Sure Your Hospitality Business is Ready for ECGT

The Empowering Consumers for the Green Transition Directive is more than just a piece of legislation; it represents a key shift in how we talk about sustainability. Here, we break down what it means for hospitality businesses and how they can prepare.

What is the Empowering Consumers for the Green Transition Directive?

The Empowering Consumers for the Green Transition Directive (also called ECGT or ‘EmpCo’) is a European Union law (EU 2024/825) designed to prevent greenwashing and protect consumers from vague or deceptive environmental claims. The rules apply to business-to-consumer communications across the EU and will come into full effect from 27th September 2026. Its purposes are:

to protect consumers against unfair commercial practices such as greenwashing, premature failure of goods, and unreliable sustainability labels, and
to provide consumers with clear and trustworthy information about the environmental, social, and circular impacts of products and services.

Non-compliant businesses may face compliance notices, fixed payment notices and prohibition orders. There is also the potential application of fines up to 4% of turnover or €2 million for widespread infringements.

What does it cover?

Under the ECGT Directive, the following will be prohibited:

1. GENERIC ENVIRONMENTAL OR SOCIAL IMPACT CLAIMS WITHOUT PROOF.

Phrases like “eco-friendly,” “green,” “climate friendly,” “carbon neutral,” “biodegradable” or “energy efficient” cannot be used unless the business can demonstrate recognised excellent environmental performance (for example, through the use of a robust and credible third-party certification).

The same rule applies to claims about social impact; for example, messaging about adequate wages, social protection, the safety of the work environment, respect for human rights, DEI and ethical commitments, such as animal welfare. This can even cover the labels vegan/vegetarian if the business is using them to make implicit claims about being better for the environment (e.g., “better for the planet”) or for society (“better for animal welfare”).

This also includes claims around future environmental performance, if they're not backed up by detailed information about how and when this performance will have an impact. This information needs to be verified and regularly monitored by an independent third party, and needs to be made publicly available.

2. CLIMATE CLAIMS BASED ON OFFSETS.

For years, brands have marketed products as “carbon neutral” by calculating their emissions and buying carbon credits to “offset” them. The ECGT Directive will ban this practice. Now, a company cannot advertise that its product has a neutral, reduced or positive climate impact if that claim relies on carbon credits purchased outside its own value chain.

Companies can still share their efforts to reduce emissions, but the focus must be on actual, measurable and verifiable reductions within their own supply chain (Scope 1, 2 or 3 emissions). You cannot pay someone else to reduce emissions for you and then claim the credit.

It is still possible to make claims that a product is "climate neutral", "climate reduced” or “climate positive” but these claims must be based on the actual emissions footprint of the product itself, taking into account its value chain and actual lifecycle impact.

3. SELF-MADE SUSTAINABILITY LABELS THAT DON'T MEET ECGT CERTIFICATION STANDARDS.

The ECGT Directive prohibits the use of any sustainability label that is not based on a certification scheme or established by public authorities. (If it was established by a non-EU public authority, the label must be based on a certifications scheme.) To use any environmental label, it must meet ECGT requirements for a certification and be verified by a third party. The certification process itself must be transparent, open to all, and audited. We are proud to say that the Food Made Good Standard and all of our associated processes were checked this summer by our audit partners at Intertek, and we can confirm that our label meets all of the standards and can be used with confidence.

4. CLAIMS ABOUT THE WHOLE WHEN ONLY A PART QUALIFIES.

Stating that a product is “made with recycled material” when only the packaging is recycled, for example, is considered misleading. For hospitality, this could mean making a claim about a hotel as a whole when that claim doesn’t cover the F&B offering, or making a claim about a whole group when certain sites don’t meet the criteria. For example, making a generalised claim like “We only source locally” could be an issue as it doesn't specifically state "food", so this could be misleading if your cleaning products or toiletries come from further afield.

5. PRESENTING LEGAL REQUIREMENTS AS SPECIAL FEATURES.

Advertising compliance with a regulation as though it were a distinctive selling point is prohibited; for example, you can't advertise that the water served in your restaurant is “safe for human consumption” when it is legally required to be so. It's also not permitted to advertise a benefit that is not directly related to the product or has no relevance, e.g., claiming that water is “gluten-free”. This is one reason why the Food Made Good Standard focuses on actions that move beyond compliance, encouraging best practice and, in the process, providing businesses with a solid, ECGT-compliant foundation for their communications.

Only consumer-facing communications are covered. For example, these rules do not apply to corporate-level reports you may prepare for your stakeholders — but the moment any part of this content is reused in consumer-facing marketing, it falls within the scope of the ECGT.

What about businesses outside the EU?

Because the ECGT Directive is an EU law, you may think that it only applies to EU companies. However, the legislation explicitly covers any business engaging in commercial practices towards EU consumers. For example, if you’re a hotel advertising to European customers, you must comply — regardless of where you are in the world.

Because non-EU businesses must now comply with ECGT in order to sell to European consumers, the standards specified may become a new ‘norm’ across multiple markets. What’s more, the EU is one of the most progressive global regions when it comes to environmental legislation, and regulations that are first seen in the EU are often replicated elsewhere. Ultimately, this legislation may act as a blueprint for other parts of the world in strengthening their own consumer protection frameworks, with the effects of the ECGT rippling out far beyond European borders.

What does the ECGT Directive mean for hospitality?

This signals the beginning of a more mature era for sustainable hospitality: one with greater transparency and accountability. Now, action matters more than intention, and sustainability work needs to deliver real, measurable change.

This shift towards greater accountability is not bad news for hospitality; on the contrary, we believe it represents an opportunity. Sustainability work already has the potential to deliver better margins, increase reputation and customer trust, and build strong, future-fit businesses. Raising our collective expectations cuts out the background noise, meaning that those restaurants who are truly doing this work can also share it in credible ways that resonate with the modern diner, earning the recognition they deserve and, ultimately, raising standards across the industry.

Going forward, it may seem like the safer option is simply to stay quiet about your ESG initiatives — but this creates its own risks. Staying silent looks like indifference or, worse, avoidance, particularly at a time when climate action feels increasingly urgent.

Furthermore, a culture of silence around sustainability does nothing to drive the industry forward. For hospitality, sustainability work is hard and it is ongoing. To encourage the sustained, long-term change that we need across the sector, it's crucial that we continue to celebrate real progress. 

So how can operators stay on the right side of the ECGT?

An important first step is to remove any vague or misleading social or environmental claims from your consumer-facing communications — immediately. This includes your website, menus, social media, posters, stickers, point-of-sale information and, if you produce any of your own packaged goods for sale, your packaging. Be particularly vigilant in looking for any buzzwords like “green”, “eco-friendly” or “carbon-neutral”. If you are a large European operator, you should act with urgency. Update your marketing and PR teams to be clear with them what things they can and cannot say, and ensure that your ESG team has explicit sign off on all marketing materials.
Review any environmental labels you currently use to communicate your sustainability initiatives. Make sure that those you do use are based on credible certification schemes that meet ECGT requirements. You should be able to confirm this by looking at the scheme’s terms, which should be publicly available (i.e., on their website). Delete any self-created or unverified "eco-badges" or labels from your communications. (As part of the updates to our Food Made Good Standard, we have introduced a second layer of evidence review to ensure that the certification is ECGT-compliant. You can read more about this here.)
Going forward, make sure your sustainability communications are specific, substantiated, transparent and consistent.
Gather concrete, documented proof for every active claim, such as energy or waste reduction metrics or the percentage of your food that is sourced locally (and how you’re defining “local”). Make these data readily available to the consumer. This is where Food Made Good can help; for those of you who have completed the certification process, we’ve already reviewed lots of your evidence, which we know wasn’t always easy to gather. We can help you understand what is substantiated enough to state publicly and what isn’t.
Be careful that you don’t make whole-business claims for department-specific actions. If a practice only applies to one part of your business, be clear about that. (As an example, don’t use a blanket statement like “We use renewable energy” if your kitchen still uses gas hobs.)
Even if you’re sure that specific claims meet ECGT standards, don't just copy and paste corporate or investor ESG data into guest-facing marketing materials. This is an opportunity to engage your customers while meeting ECGT requirements, so make sure your communications are not only backed by evidence, but interesting, too. Think carefully about the story you want to tell, then be specific in how you communicate it — no vagueness.
Use certification schemes as an honest verification of your actions. Robust and action driven frameworks like Food Made Good show that your brand has been through a rigorous review. Lean into sharing that process with your customers.

Join our free webinar to learn more about ECGT

Sustainability Communications in a Post-Greenwashing Era: What ECGT Legislation Means for Your Business

It’s our pleasure to invite you to a free online webinar exploring how hospitality operators can navigate sustainability communications safely and effectively. In this session, The SRA will show why the smart way forward is to focus on transparency and accountability, using robust frameworks to communicate your hard work in credible ways. The session will be hosted by our CEO, Juliane Caillouette Noble, and our Head of Global Certification, Julia Holiday.

What to expect:

Learn what the EU’s new legislation, the Empowering Consumers for the Green Transition Directive (EGCT), means for your business — even if you’re not based in the EU.
Understand the impact of smart sustainability communications on customer perceptions, staff recruitment and retention, and investor decision-making.
Learn what makes sustainability communications strong and effective.
Hear how robust frameworks can underpin and inform your sustainability communications.
Learn how the Food Made Good Standard can support your business by assessing behaviour, measuring action, guiding next steps and celebrating progress.

This webinar is free to attend; simply register to secure your place.

If you have any questions about how Food Made Good could provide the credibility you need to communicate with confidence about your sustainability work, get in touch! You can email us at hello@thesra.org, Whatsapp us on 0044-7822014415 or use our contact form here.

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