HOW THE EMPCO GUIDELINES AFFECT THE TRAIL ANGELS’ COMMUNICATIONS.
New rules,
same path.
Anyone who has spent time on our websites, www.trail-angels.com and www.bookyourtrail.com, has probably come across terms such as “sustainable tourism”, “Green Spirit” or “hiking without a footprint”. These ideas have been a core part of who we are ever since our company was founded.
That is why it may seem surprising that these terms will appear much less frequently, or perhaps barely at all, in future on our websites, in trip descriptions and in our marketing materials.
Has our philosophy changed?
No. What has changed are the legal conditions that govern how we communicate.
With the new EU Directive “Empowering Consumers for the Green Transition” (EmpCo), and the resulting amendments to competition law, consumers are to be better protected against greenwashing. We explicitly support this objective. At the same time, the upcoming implementation presents new challenges, which we would like to address openly here. From September 2026 onwards, the directive is set to apply throughout Europe and will significantly tighten the requirements for environmental and sustainability-related claims, particularly in tourism. General statements such as “sustainable”, “green” or “environmentally friendly” may only be used under highly restrictive conditions. In addition, even international sustainability labels must be based on recognised ISO certification systems.
Our focus is on the development, design and operation of products that incorporate resource-conserving practices. However, a hiking holiday does not have to be ‘sustainable’ per se and must not be advertised as such. This can be summarised as the key message of the new EmpCo guideline; ©TVB Gesäuse/Stefan Leitner
GREENWASCHING HARMS EVERYONE
Why we support the Directive
It harms travellers seeking honest guidance. It harms companies that genuinely invest time, money and commitment. And ultimately it harms the tourism sector as a whole because it erodes trust. For this reason, we welcome the objectives of the EmpCo Directive. Sustainability claims should be transparent, verifiable and credible. Companies should no longer be able to advertise with vague promises that have little substance behind them.
Why Implementation Is Particularly Challenging for SMEs
As the implementation date approaches, many small and medium-sized tourism businesses are experiencing growing uncertainty. The new regulations are complex, while many detailed legal questions remain unanswered. At the same time, there is still a lack of consistent standards and clear guidance. In practice, the boundary between legitimate information and potentially problematic marketing claims is often unclear. Large corporations may have extensive legal and sustainability departments at their disposal. For specialised tour operators such as Trail Angels, however, the new legal framework creates a considerable organisational and financial burden.
The Trail Angels are Travelife certified
A specific example: Travelife certified. Travelife is internationally recognised as one of the leading sustainability programmes for tour operators and is aligned with the criteria of the Global Sustainable Tourism Council (GSTC). Nevertheless, an important legal uncertainty currently exists. Under the new rules, sustainability labels will be assessed according to whether they fulfil the required criteria of independent ISO-based certification systems. Many tourism certifications, including Travelife, are currently undergoing review and alignment processes to ensure that future requirements are fully met. As a result, their validity within the framework of the EmpCo Directive remains something of a grey area.
This does not mean that the certification has lost its value. It simply means that, despite our certification and the efforts behind it, we must be especially careful in how we communicate. For Trail Angels, as you can imagine, this is not an especially reassuring situation.
Greenwashing is more than just a façade with nothing behind it. It is a deliberate deception that knowingly harms the concept of sustainability in tourism. For this reason alone, we support the overarching goal of the EmpCo Directive. © K. Dapra
Implementing the EmpCo guideline is a complex process, not least because a number of legal issues have yet to be definitively resolved. This naturally dampens the enthusiasm of Trail Angels’ COO Nathalie Reichhold (pictured here at the 2024 awards ceremony)…©Travelife
Our path forward: Keeping the Direction, adapting the communication
This is exactly why we are currently reviewing and adjusting all of our communication step by step. In future, we will use broad terms such as “sustainable” or “sustainable tourism” more cautiously.
Not because our products have become any less sustainable, and not because we question the goals behind these ideas, but because we need to avoid legal risks.
In our new communications strategy, we have opted for the term ‘responsible tourism’. This includes, amongst other things, our responsibility towards our 1,000 partner businesses, which benefit directly from our mission and daily work on long-distance trails. ©Franz Gerdl/Kärnten Werbung
What Trail Angels continues to stand for
Regardless of the language we use, our fundamental direction remains unchanged. The pillars on which we develop responsible outdoor experiences remain the same:
- We focus on hiking, cycling and outdoor travel, forms of travel that generally require comparatively few resources.
- We actively promote arrival and departure by train and public transport wherever this is practical and meaningful.
- We work primarily with small family-run accommodations, regional service providers and local partner businesses.
- Our trails create value along the route and strengthen peripheral and rural regions through transparent and fair business models.
- For selected products, we provide guests with the option of calculating the CO₂ footprint of their trip, creating greater transparency.
- And, of course, we remain a Travelife-certified tour operator.
Each of these pillars is concrete, understandable and open to verification.
Our mission remains the same
We are convinced that tourism products such as long-distance hiking trails and cycle routes can provide important answers to many of the challenges facing the tourism industry of the future. The new EmpCo Directive changes only the language we use when talking about these issues.
It does not change our mission. In fact, it strengthens it.
We will continue to do everything we can to develop trails based on resilient and participatory management models that inspire travellers, strengthen regions and make the most responsible use of resources possible.
Perhaps our branding will look slightly different in the future. Perhaps certain terms will disappear. But our direction remains exactly the same.
Whatever terms we use in future, we will continue to work consistently towards. Step by step, we are moving towards responsible and forward-looking outdoor tourism. ©Kärnten Werbung/Stabentheiner
YOUR MESSAGE TO US
Contact
Every great journey begins with the first click. If our projects for responsible outdoor tourism have inspired you, or if you would like to actively experience one of our fascinating trails, simply get in touch with us. Whether you are a future project partner or a traveller, you will see: our journey together begins with the first click!