Inequitable Access to Sustainability Certification: Implications for the Implementation of European Greenwashing Legislation

This study examines potential unintended consequences of the EU Empowering Consumers for the Green Transition Directive (approved) and the Green Claims Directive (stalled) on the hotel sector, revealing that sustainability certification is concentrated among large, high-end, chain-affiliated hotels. Small and independent hotels face significant structural barriers—such as high costs, limited resources, and lack of support—that risk excluding them from making environmental claims. Without targeted policy interventions, both directives could entrench inequities and marginalise under-resourced businesses. Using real options theory, the report identifies four strategic responses: wait and see, partial investment, growth, and withdrawal. It calls for inclusive policy design, accessible certification systems, and coordinated stakeholder action to ensure equitable implementation