Can We Still Say 'Sustainable'?

Picture a statement like: 'We are a sustainable hotel.' What exactly does that mean? Does it refer to energy use? To food sourcing? To working conditions? To mobility? To water consumption? To waste? To the way the building was constructed? Or to all of these areas at once? That is precisely where the problem lies: the broader a claim, the greater the expectation it creates among consumers — and the harder it becomes to verify.

A substantially better way to communicate might be, for illustrative purposes only: 'Since January 2025, our hotel operations have sourced electricity from renewable sources,' or 'Our water consumption per overnight stay in 2025 was 14 percent lower than in 2023' — figures used here purely as hypothetical examples of the kind of specific, evidence-based wording companies should aim for, provided such statements can actually be substantiated. These formulations may look less spectacular at first glance. In practice, they are usually stronger, because they actually say something.

The directive makes clear that a generic claim does not become specific simply because an explanation exists somewhere else. The specification must appear clearly and prominently on the same medium for a claim to avoid being treated as a generic environmental claim. The directive itself offers an illustrative example: 'climate-friendly packaging' is generic, whereas a concretely described property — such as the use of renewable energy during manufacturing — is far more specific.

For every word like 'sustainable,' ask four questions: What exactly do we mean? Which specific area does the statement cover? Can we actually demonstrate this specific property? Will a customer understand the same thing we mean, on first reading? If any of these questions is hard to answer, the claim should be reviewed before it is published again.

This may be the biggest misunderstanding in the current debate. Good communication does not mean stacking up as many positive adjectives as possible. Good communication describes what is actually happening. Not 'We consistently focus on sustainability,' but something closer to, as a hypothetical illustration: 'Since 2022, we have removed single-use items from our procurement.' The second statement is more concrete, more credible, and more interesting — and that is precisely the opportunity in the new rules: sustainability communication can move closer to describing real change again. Our principle at VERDAI is simple: say less, more precisely, rather than more, less precisely.

EmpCo primarily complements the rules for commercial practices directed at consumers. Check the applicable national implementation separately; Germany’s UWG does not automatically govern claims in other countries. Precise wording alone does not replace matching evidence or a responsible person’s decision before publication. Review the overall impression, including the heading, image and immediately visible explanation. Automated findings do not approve a claim.