GDS-Movement Updates Guide to Help Destinations Navigate EU Greenwashing Rules

The revised edition of Proof, Not Promises incorporates updated legal analysis and an eight-principle framework to help tourism and events organisations substantiate environmental claims and communicate sustainability progress with greater transparency.

The European Union’s new rules on environmental claims are raising the bar for how tourism and events organisations communicate their sustainability commitments. For destination management organisations, convention bureaux and tourism businesses, the challenge is no longer confined to setting environmental targets: they must also ensure that the claims used to describe their progress are specific, verifiable and supported by credible evidence.

Against this regulatory backdrop, the Global Destination Sustainability Movement (GDS-Movement) has released an updated edition of Proof, Not Promises: A Practical Guide to the EU Empowering Consumers Directive for Destinations, developed in collaboration with the European Travel Commission (ETC) and NECSTouR. The publication responds to the application, from 27 September 2026, of the EU Empowering Consumers for the Green Transition Directive (EU) 2024/825, commonly known as EmpCo.

The legislation strengthens consumer protection against misleading environmental claims and introduces more demanding requirements for sustainability communication. Organisations must be able to substantiate what they say, avoid vague or unqualified environmental statements, and provide clear information about the basis of their claims.

The revised guide builds on the first edition, released in April 2026, incorporating updated legal analysis and lessons gathered through GDS-Movement's subsequent consulting projects and sustainability storytelling masterclasses for city and national tourism organisations. Discussions with European Union representatives, industry associations and project partners have also informed the new material.

Guy Bigwood, CEO of GDS-Movement, points to the practical implications of the regulatory changes for destinations and their communication teams.

“Working with destinations and industry partners over the past six months has reinforced one important lesson: the challenge is not simply understanding the new rules, but putting them into practice. Sustainability communication must move beyond good intentions to credible claims backed by evidence. Our message is simple: don't withhold or stop communicating your progress. Be more specific, more transparent, and better prepared to prove it.”

GDS-Movement Launches New Guide on EU Sustainability Claims Rules

From legal interpretation to practical guidance

The updated edition introduces five main areas of development. These include a more detailed analysis of how EmpCo is being implemented across EU Member States, with attention to differences in national approaches and potential enforcement risks, as well as clearer guidance on the organisations and activities covered by the legislation.

The publication addresses destination management organisations, convention bureaux, public bodies acting commercially, tourism businesses and event organisers. It also expands its practical examples, examining environmental claims that carry higher risks, climate commitments, the avoidance of greenwashing and responsible ways of communicating sustainability progress.

A central addition is the CREDIBLE Claims Framework, which now sets out eight principles to help organisations assess their environmental claims, strengthen supporting evidence, identify risks, align internal teams and improve their communications. This builds on the original six-step framework and gives organisations a more structured approach to putting the guidance into practice.

The revised publication also provides deeper explanations of sustainability labels, independent verification, credible certification and accreditation, areas of particular relevance as the new rules tighten requirements around environmental labelling.

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The risk of green hushing

One of the guide's central arguments is that stricter regulation should not discourage organisations from communicating genuine environmental progress. The phenomenon of green hushing – the reluctance or decision not to communicate sustainability initiatives for fear of making misleading claims – can leave meaningful work invisible to visitors, clients and local communities.

The alternative proposed by GDS-Movement, ETC and NECSTouR is communication grounded in reliable evidence, precise language and transparency about both achievements and limitations. This also requires coordination across organisational functions. Sustainability teams cannot carry the responsibility alone: operations, data and marketing departments need to work together to ensure that public statements accurately reflect what an organisation is doing and can demonstrate.

Certification is another area requiring careful interpretation. EmpCo does not oblige every organisation to obtain sustainability certification. However, it introduces stricter conditions for sustainability labels and reinforces the importance of independent verification and credible evidence when environmental credentials are communicated.

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An opportunity to strengthen trust

For destinations and event organisations, the implications extend beyond regulatory compliance. Sustainability claims influence how visitors, association clients, event organisers and local communities assess a destination's commitments and performance. The ability to communicate progress accurately is therefore closely connected to institutional credibility and stakeholder trust.

By bringing together legal analysis, practical examples and a framework for assessing environmental claims, Proof, Not Promises seeks to help organisations develop the internal capabilities needed to communicate with greater confidence. The updated guide positions the new regulatory environment as an opportunity to improve transparency and strengthen the relationship between sustainability commitments and the evidence presented to support them.
 

The updated publication is available through the GDS-Movement reports library, with a summary of the guide also available online.
 

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