Across the European Union, regulators are taking a hard look for signs of greenwashing, or making false or misleading claims about a product, firm or business’ claims of environmental benefits.
Now, Germany is introducing tougher criteria for hotels to demonstrate their climate commitments and earn eco-certification.
In June 2024, the Federal Court of Justice — Germany’s highest court of civil and criminal jurisdiction — outlawed the unsubstantiated use of the term “climate neutral” in advertising.
Climate claims now must be backed up by detailed proof of emissions from energy consumption and other sources, such as waste disposal and laundry cleaning. This new legislation has profound ramifications for the hotel industry.
In Germany, one of Europe’s traditionally greenest countries, only approximately 2,000 hospitality accommodations options openly show their climate commitments to guests with certification, according to the German National Tourism Board. That's approximately 15% of the country’s 12,000 hotels. Compare that with the 30% of French hotels that have the correct eco-certification.
German hoteliers said they are doing all they can to stay ahead of a new EU ban on greenwashing and misleading labeling in businesses, including hotels.
The Green Claims Directive is set to go into effect on Sept. 27, 2026, but hotels throughout the EU are required to comply by the rules by March of this year. The stricter regulations on environmental claims align with Germany’s climate law and goal to reach net-zero emissions by 2045.
Despite Germany's push to comply, some question whether more could be done to meet the EU's climate-certification requirements.
In 2023, Munich-based climate consultancy ClimatePartner stopped certifying hotels with its former “carbon neutral” label. Its founder and managing director, Moritz Lehmkuhl, said the ClimatePartner-certified label is a step toward meeting EU regulations.
“To receive the label, hotels will have to demonstrate they are implementing reduction measures in their own supply chains and have set long-term reduction targets. A Financial Climate Contribution label indicates an investment in climate projects not aimed at offsetting,” he said.
The 86-room Aramis Conference & Sports Hotel in Gäufelden, close to Stuttgart, was recently recertified through ClimatePartner. The hotel met the recertification criteria by conducting an analysis of its carbon footprint detailing emission reduction measures and offsets, said its managing director Michael Dengler.
“This provides transparent disclosure of our entire climate protection strategy, including the carbon footprint, reduction targets, reductions implemented and the financial contribution to climate protection projects worldwide,” he said.
The hotel continues to monitor and analyze its energy consumption after installing LED lighting, with the aim being to use at least 80% green electricity by 2025 and 100% in 2030, Dengler said. By 2028, it will rely on renewable energy for heating.
No loopholes
Some German hoteliers continue to speak of carbon neutrality without showing evidence of reducing emissions. It's this kind of vague terminology the EU wants to rule out.
The EU has placed emphasis on offsets, but there are loopholes such as compensating for continuing emissions by financing emission-reduction projects overseas — although that practice can be beneficial to the overseas location of choice.
“This should always be the last step, and it should not detract from taking action in reducing your footprint in the first place,” said Ben Förtsch, hotelier at the 92-room Hotel Luise in Erlangen, Bavaria.
Since 2017, Hotel Luise has used a rooftop photovoltaic system — a type of solar technology — to generate its own energy while relying on energy-efficient heating from local utilities. In 2023, it was awarded the EU Ecolabel certification and became the first climate-positive hotel in Germany, Förtsch said.
Hotel Luise's climate certification does not rely on offsets, he said. The hotel minimizes its footprint by utilizing renewable energy sources.
“We overcompensate and offset our emissions not as part of the certification processes but from a social perspective, to fund and support projects in countries where the effects of climate change are more evident and where these sustainable practices can help the local community,” Förtsch said. “I don’t think the EU is trying to put an end to that but rather prohibit greenwashing by only offsetting emissions without showing proof of it being the last step in many sustainable measures to reach net-zero targets.”
Soon, all hotels in the 27-member European Union bloc must be certified by the EU itself or by an EU-approved body, which likely would create a flood of new audits.
Michael Stober, managing director and owner of the 300-room conference hotel Landgut Stober in Nauen, near Berlin, said recertification is nothing new.
“An audit takes place at least every three years to ensure we are achieving our sustainability goals,” Stober said. “If the certification reveals deficits, the hotel works on them.”
In the latest audit, the hotel scored 4,702 out of 5,000 possible points.
For Stober, transparency is key.
“The CO2 balances are published, as are all certifications of third-party reports,” he said, adding his hotel is “almost energy self-sufficient.”
“Since 2018, we have been offsetting more CO2 on-site than we use to operate the hotel. A photovoltaic system generates electricity, the toilets are flushed with rainwater, and heat comes from wood chip heating,” Stober said.
There are a few sustainability pioneers in the hotel industry, mostly due to most hotels only now focusing on the first steps towards sustainability, Lehmkuhl said.
“Net zero should now be the overarching global goal,” he said.
The stakes and effects of climate change are rising, he added.
“Corporate carbon accounting is an increasingly important issue in the hospitality industry, driven by legislation such as the EU’s Corporate Sustainability Reporting Directive and demand from business customers,” Lehmkuhl said. “We are helping some major hotel chains to conduct a detailed analysis of their CO2 emissions and to develop a comprehensive decarbonization plan.”
Stober is one hotelier who has recently received for his hotel Global Sustainable Tourism Council certification.
“It was important to us to obtain a certification conforming to international standards,” he said.
Hotels that fail to “will not survive,” he added.