In this episode, Kathy Sue McGuire talks with Daja Apetz-Dreier, co-leader of Morgan Lewis' ESG and Sustainability Advisory practice in Munich, about the EU's new anti-greenwashing law and why it reaches US hotels, resorts, and DMOs.
The Empowering Consumers for the Green Transition Directive (EmpCo) becomes binding September 27, 2026. The conversation covers who is in scope, why "carbon neutral" and "eco-friendly" are now high-risk phrases, and what US hospitality should do before the deadline.
CHAPTER BREAKDOWN
00:00:02 — Welcome & Introduction
Meet Daja Apetz-Dreier and the law behind the headlines.
00:00:45 — What Is the EmpCo Directive?
The EU's anti-greenwashing consumer law, in plain terms.
00:01:23 — Why a European Law Reaches US Hotels
A hotel in Arizona isn't automatically in scope. Targeting EU consumers changes that.
00:04:17 — Three Risk Areas
Vague green language, unverified labels, offset-based claims.
00:05:17 — Self-Created Seals vs. Real Certification
Why invented logos implying independent review are the target.
00:06:25 — OTA Badges & the Certification Problem
How booking platforms flatten tiered scores into one badge.
00:10:15 — "Carbon Neutral," "Net Zero" & Offsets
The riskiest claim category, and how to replace slogans with measurable statements.
00:13:08 — Is Certification Mandatory?
Substantiation vs. certification, and what counts as real evidence.
00:14:36 — GSTC & Accredited Certification Bodies
It's not just the scheme you pick — it's who accredits it.
00:17:45 — Fines, and the Bigger Risk
Up to 4% of global turnover, but reputation may cost more.
00:19:40 — The Food Export Analogy
US brands already reformulate to sell into the EU. Marketing is no different.
00:22:02 — What Counts as "Targeting" EU Consumers?
Language, currency, booking capability, and where courts may draw the line.
00:26:28 — DMOs, Tour Operators & Campaigns
German-language campaigns put vague eco-claims squarely in scope.
00:30:05 — A LEED Building ≠ a Sustainable Event
Certifying the structure says nothing about operations inside it.
00:33:06 — What to Do Before September 27
Have the data, match claims to evidence, validate independently.
00:39:30 — Final Thoughts
Find out whether you're in scope, then decide.
🔗 Resources & Links
EmpCo Directive (EU) 2024/825
Morgan Lewis
GSTC
Whole Systems Hospitality Podcast
👤 About the Guest
Daja Apetz-Dreier is co-leader of Morgan Lewis' ESG and Sustainability Advisory practice in Munich, Germany. She advises companies on climate change, greenwashing, and regulatory matters.
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