A drawn green leaf, “sustainable hotel” and “carbon-neutral stay”. Europe has put all three on the list of things that cannot be done.

Picture this: a five-star resort in Mallorca with a largely British clientele. On the homepage of its website, a green leaf the agency designed four years ago, with the word “Sustainable” underneath. On the rooms page, “carbon-neutral stay”, because the hotel buys offset credits every winter. And on the German version, “umweltfreundliches Resort”. Nobody is knowingly lying. It is simply that nobody has read it again.

For years, phrases like these were decoration. I think that is over, and not only because of the law: the guests who pay the most are also the ones who ask most about what lies behind each word.

What the directive says.

Directive (EU) 2024/825, which protects consumers in the green transition, amends the EU list of commercial practices considered unfair in all circumstances. Member states had to transpose it by 27 March 2026 and apply it from 27 September 2026. Among other things, it adds four practices to that list:

• A home-made sustainability label. Displaying a label that is not based on a certification scheme and was not established by a public authority.
• A generic claim without proof. Saying something is good for the environment without being able to show recognised excellent environmental performance.
• The part for the whole. Presenting as true of the whole business something that concerns only one aspect or one specific activity.
• Neutrality through offsetting. Claiming a neutral, reduced or positive emissions impact on the basis of offsetting.

The directive itself gives examples of generic claims: “environmentally friendly”, “green”, “eco-friendly”, “climate friendly”, “energy efficient”. And it adds that words such as “sustainable”, “responsible” or “conscious” cannot rest on excellent environmental performance alone either, because they also refer to social aspects. What counts as “recognised excellent” is, for example, meeting the EU Ecolabel, which has its own criteria for tourist accommodation, or an official type I ecolabel.

There is a way out, and it lies in the definition. A claim stops being generic when it is specified in clear and visible terms on the same medium. The problem is not talking about what the hotel does. It is talking in adjectives.

Where Spain stands.

On 1 July 2025, the Spanish Council of Ministers approved at first reading the draft Sustainable Consumption Law, which transposes this directive and bans claims such as “environmentally friendly”, “green” or “biodegradable” when they cannot be verified. As of 13 October 2026, I have found no published Spanish law that transposes it. And a royal decree of 5 October dissolved the Spanish parliament and called elections for 29 November.

What I do not know.

I do not know when the Spanish law will arrive or with what final wording. I do not know how much weight the directive will carry in a dispute before then: that is a question for your legal counsel, and I am not a lawyer. Nor do I know how far it reaches a Swiss hotel selling to European guests. What I do know is that the list of practices is written, has a date, and will not be softer once it is transposed.

The blind spot: not just the text.

The directive treats as an environmental claim any message, including a drawing, a symbol, a trade name or a product name. A green leaf in the logo, an “Eco Suite” or a spa called “Green” all count. And they count in every language: the phrase corrected in English may still be alive in the German version, in a listing on an online travel agency or in the 2022 PDF brochure that can still be downloaded from the website.

An adjective cannot be checked. A figure can.

Where I stand.

I would not wait for Spanish law. I would rewrite the hotel website now, replacing each adjective with a fact that has a scope and a date: what share of the electricity comes from renewable sources and under which contract, which certification the hotel holds, with its name and a link, what is offset and how much, without calling it neutrality. Whatever cannot be documented comes down. A luxury hotel loses nothing by being precise. It loses a great deal if an attentive guest discovers that its green leaf was drawn by an agency.

What I would check.

• The words. Green, eco, sustainable, responsible, carbon neutral and their equivalents, in every language of the website.
• The labels and symbols. Which badges appear, who awards them and what certification lies behind them.
• Offsetting. Any phrase about neutrality or positive impact based on buying credits.
• The part and the whole. Whether one specific improvement, such as the spa’s solar panels, is presented as if it applied to the whole hotel.
• Beyond your website. Online travel agency listings, downloadable brochures and the names of rooms and services.

Where to start.

1. Today

   Search for the words

   In every language of the website and in the PDFs, note each environmental claim and where it appears.

2. This month

   Gather the proof or remove

   For each claim, the document that backs it. No document, no claim.

3. This quarter

   Rewrite with data

   Specific sentences with scope and date, reviewed by your legal counsel.

4. Every year

   Update the figures

   Each published figure with its date, reviewed whenever the contract or the certification changes.

Search your website for the word “sustainable” in all your languages, and look at the icons too: the green leaf, the globe, the seal someone added to the footer. For each one, ask yourself a single question: can I show the proof today to anyone who asks?

Whatever fails that test may not be a lie. But since 27 September 2026 it is no longer an innocent sentence either. What real figure, however modest, could take its place?

If you would like me to review what your website says about sustainability today, in every language, and how to tell it with data, start with the Strategic Diagnostic. Whether a specific claim is lawful in your case is for your legal advisers to decide, not a designer.