One sentence that changes a lot
If your platform shows an EU consumer a sustainability label, badge, or certification — for a hotel, a tour, an activity, or your own marketplace program — that label must now meet one of two conditions:
It is established by an EU public authority, or it is backed by a certification scheme that meets a minimum set of governance, transparency, and independent verification requirements.
Anything else is prohibited. Not regulated. Not monitored. Prohibited — classified as an unfair commercial practice.
This matters specifically for tourism marketplaces because the platform is often where the label is actually shown: on listing cards, in search filters labelled "eco-certified," on property pages, in marketing emails. That makes the platform's UI and marketing part of the consumer-facing commercial practice the Directive is targeting — regardless of where the certification originally came from.
What makes a certification scheme acceptable
For a private sustainability label to remain usable after September 2026, the scheme behind it must meet all of the following:
Minimum requirements for a private certification scheme to qualify:
Based on independent third-party verification — not self-assessment, not questionnaire-only
Requirements and terms are publicly available
Compliance is monitored by a competent, independent third party, aligned with recognized standards (the Commission references ISO 17065)
Open to all traders on fair, non-discriminatory terms — non-exclusive by design
Requirements set in consultation with relevant experts and stakeholders
Explicitly authorizes use of the corresponding label
Note: what matters is not where a certification scheme is based, but where its certified properties are marketed. If a scheme's hotels appear on EU-facing platforms, the scheme falls within scope of the Directive — regardless of its country of origin.
Four concrete changes for tourism businesses
Self-made badges become high-risk
"Sustainable Choice," "Eco-Leader," "Certified Green" — badges based on supplier questionnaires or light checks are exactly what this Directive was written to stop. If there is no robust independent verification behind it, it is prohibited.
"We'll show whatever the hotel uploads" no longer works
Marketplaces need an allowed-label policy: a curated list of accepted schemes, or a scheme-approval workflow. Displaying prohibited labels at scale creates regulatory exposure across the entire inventory.
Origin doesn't determine compliance — distribution does
A certification scheme based outside the EU still needs to meet the Directive's criteria if its certified properties are displayed on EU-facing platforms. Being listed on an OTA that serves EU consumers brings the label into scope — regardless of where the scheme was created or which markets it primarily operates in.
No grandfathering after 27 September 2026
There is no transition period for non-compliant schemes already in use. Labels must comply by the application date or be removed. The FAQ is explicit on this point.
The implications differ — but both segments need to act
The display layer is your liability
- Inventory every sustainability badge and filter currently shown to EU consumers: listing pages, search filters, property pages, and email campaigns
- Build a scheme-approval workflow to classify labels against the criteria
- Implement verification status checks: valid certificate, expiry date, scope
- Set up removal/expiry handling — a lapsed certificate must trigger badge removal
- Audit marketing creatives and email templates for prohibited claims
Your certifications are only as safe as the scheme behind them
- Audit every active certification: does the scheme meet the compliance criteria?
- Identify which certifications can still be claimed and displayed after September 2026
- Brief your distribution partners on which labels they may continue to show
- For non-compliant certifications: plan migration to accepted schemes before the deadline
- Ensure your sustainability data infrastructure can demonstrate compliance if challenged
What to do between now and September 2026
Label inventory
Map every sustainability label, badge, filter, and marketing claim currently displayed to EU consumers. Include listing pages, search filters, property pages, and email campaigns.
Classification
Classify each label: EU public authority vs. private scheme. For private schemes, collect evidence against the certification criteria and make a keep / replace / remove decision.
Supplier or partner engagement
For labels you rely on partners to supply: define what evidence you need from them. "We have a badge" is not sufficient. You need documentation that the underlying scheme qualifies.
Build the ongoing process
A one-time review is not enough. Certification statuses change. Schemes evolve. You need a label intake process, ongoing verification status tracking, and expiry handling built into your operations.
Walk through your label inventory with us
BeCause maps certification data across your portfolio against the Travalyst-recognized list of compliant schemes — giving you a clear starting point for understanding where your labels stand before the September 2026 deadline. Book a 30-minute session with our team.
Book a session →No commitment. Focused on your specific situation.
