Hotel ESG Reporting in Romania: What Applies from 2026

Overview

In 2026, ESG reporting has two faces for hotels in Romania. The EU "Omnibus" package has removed almost every company the size of a hotel or a local hotel group from the legal reporting obligation. At the same time, the requirements have migrated elsewhere: into the supplier questionnaires of international chains, the credit analyses of banks, the rules on environmental claims and the EU packaging regulation. This article sets out, with sources, what has changed, where the supply chain (Scope 3) comes in and how to build a first report that is actually useful.

What is an ESG report

An ESG report (Environmental, Social, Governance) describes how a company manages its environmental impact, its relationship with employees and the community, and how it is governed. In the EU, the framework is the Corporate Sustainability Reporting Directive (CSRD); the format is set by the European Sustainability Reporting Standards (ESRS).

For a hotel, the report covers in practice: energy and water per occupied room, emissions (Scope 1, 2 and 3), waste and packaging, working conditions, procurement policies and how management tracks these subjects. It is not a marketing document but a management tool that can be verified.

The big change: new thresholds, simplified standards, a delayed calendar

Three acts adopted between 2025 and 2026 have redrawn the framework.

1. The Omnibus I Directive (Directive (EU) 2026/470). Published in the Official Journal on 26 February 2026 and in force since 18 March 2026, it narrows the CSRD obligation to companies with more than 1,000 employees and a net turnover above EUR 450 million, cumulatively. Listed SMEs are out of scope. Member states have 12 months to transpose it.

2. The value chain cap. For information requests made for the purpose of sustainability reporting regulated by the CSRD, undertakings in the value chain with up to 1,000 employees benefit from the "value chain cap" protection: the information requested may not go beyond the set provided for in the voluntary standard. The protection applies to financial years starting on or after 1 January 2027. It does not mean that a client or partner cannot request additional information by contract or for other purposes.

3. Revised ESRS and the voluntary standard. Adopted by the Commission on 3 July 2026, the delegated acts were published in the Official Journal on 21 September 2026: Delegated Regulation (EU) 2026/1560 (the voluntary standard), in force since 24 September 2026, and Delegated Regulation (EU) 2026/1563 (simplified ESRS), which enters into force on 10 November 2026 and applies to financial years starting on or after 1 January 2027, with transitional options for 2026. The voluntary standard (VSME) is the relevant framework for undertakings that fall outside the CSRD obligation and, at the same time, the ceiling for requests covered by the value chain cap. Its use remains voluntary.

In Romania, the situation has to be kept separate from the EU rule. CSRD was initially transposed by Order of the Minister of Finance (OMF) no. 85/2024, and OMF no. 1,421/2025 postponed certain reporting waves by two years: obligations covering financial year 2025 were moved to financial year 2027, with reporting in 2028, and those covering financial year 2026 were moved to financial year 2028, with reporting in 2029. Directive (EU) 2026/470, which introduces the EU threshold of 1,000 employees and EUR 450 million in net turnover, must be transposed in Romania by 19 March 2027. The draft order put out for consultation by the Ministry of Finance on 7 September 2026 (more than 1,000 employees and more than RON 2.25 billion in net turnover) is not yet legislation in force.

In practice, a hotel with 60, 150 or 400 employees is not caught, on this criterion alone, by the EU threshold of 1,000 employees. The exact position depends, however, on the entity and the group it belongs to, and on the Romanian law applicable to the relevant financial year. The pressure comes from elsewhere.

Why it matters in 2026, even if you are not obliged

Environmental claims now have a Romanian legal act. Directive (EU) 2024/825 on empowering consumers for the green transition has been transposed into Romanian law by Government Emergency Ordinance (GEO) no. 18/2026, published in the Official Gazette no. 236 of 26 March 2026, which amends Law no. 363/2007 on combating unfair commercial practices. The rules on environmental claims apply from 27 September 2026, and the National Authority for Consumer Protection (ANPC) is the competent enforcement authority.

From that date, generic wordings ("eco", "green", "environmentally friendly") are problematic when used as generic environmental claims without the trader being able to demonstrate "recognised excellent environmental performance relevant to the claim" (Annex I point 29 to Law no. 363/2007, as amended by GEO no. 18/2026). Also banned are sustainability labels that do not come from a certification scheme or from recognition by a public authority, claims that extend to the whole product a merit that applies to only one aspect of it, and climate neutrality claims based solely on offsetting emissions.

The distinction between a generic and a specific claim matters. "Green hotel" or "eco amenities" are generic claims. A specific claim clearly stated on the same medium ("we use refillable dispensers in every room" or "product X holds certification Y no. …, valid until …") is not treated as a generic claim, but must still be backed by evidence. "Eco amenities in every room" is a generic claim: if it is used commercially, the hotel must be able to demonstrate the relevant environmental performance. The wording "The rooms use X amenities, EU Ecolabel certified, for the products included in the certification" is different, provided the certification covers exactly that product or line.

The uncomfortable part for hospitality is that many of these wordings are not written by the hotel. They are taken from the supplier's product sheet or brand presentation and reproduced on the property's website. A hotel that reproduces the claim in a commercial communication takes on the legal risk attached to that communication and must be able to support the claim with adequate evidence, even if the information was originally provided by the manufacturer.

The Packaging and Packaging Waste Regulation (PPWR). Regulation (EU) 2025/40 applies from 12 August 2026. Article 25 and Annex V point 5 prohibit, from 1 January 2030, placing on the market single-use packaging for cosmetic, hygiene and toiletry products intended for individual use in the accommodation sector. Refillable dispenser systems do not, in principle, fall into this category, but concrete compliance depends on the configuration of the packaging and the system. The status of items offered on request at reception is still being clarified; the Commission must publish guidelines on Annex V by 12 February 2027. Anyone signing a supply contract for 3–5 years is, in effect, deciding now.

Packaging and waste in Romania. In Romania, packaging obligations fall on the economic operator that, under the applicable legislation (GEO 196/2005, Law 249/2015), places the packaging or packaged products on the national market. For a hotel, it is important to check contractually with the supplier who the first relevant economic operator in the chain is and which obligations have already been met. The RON 2/kg contribution to the Environment Fund applies to the difference between the recovery and recycling targets and the quantities actually recovered or recycled, not to every kilogram of packaging. For packaged beverages that fall within the Deposit-Return System (SGR), retailers and HoReCa operators subject to the SGR rules have the obligations set out in GD no. 1,074/2021, including the RON 0.50 deposit per package.

Hotel chains have pushed their requirements down to suppliers. Accor's Responsible Procurement Charter 2026 requires suppliers to publish an annual carbon footprint under the GHG Protocol, to respond to CDP or EcoVadis, not to offer single-use plastic products and to limit packaging. Marriott holds SBTi-validated targets: a 27.5% cut in Scope 3 emissions by 2030 against 2019, and 22% of suppliers, by emissions, with science-based targets by 2028. Hilton has rated 145 key suppliers through EcoVadis and moved to large-format hotel amenities in 2024. If you operate under such a brand or sell conferences to corporations with their own targets, these requirements reach you by contract.

Banks ask for data. At the ZF ESG Summit 2026, the Chief Risk Officer of ING Bank Romania said that the lack of ESG data limits lending decisions and that the bank prioritises clients with verifiable transition plans.

What guests say. According to Booking.com's Travel & Sustainability research 2026 (32,500 respondents, 35 markets), 85% of travellers consider more sustainable travel important or very important, 35% intend to stay in accommodation with a sustainability certification, and in 2025 more than 100 million nights were booked on the platform at third-party certified properties.

Comparative example: the United Kingdom

This section is for comparison only and does not describe the legal obligations applicable to hotels in Romania. The United Kingdom has gone down the same road about a year ahead. The UK Sustainability Reporting Standards (UK SRS) were published on 25 February 2026 and are voluntary for now, with mandatory application expected for large listed companies from 1 January 2027. On environmental claims, in the United Kingdom penalties for misleading claims have reached, since April 2025, up to 10% of global turnover, and in January 2026 it was confirmed that liability extends into the supply chain: a company can be held liable for repeating its suppliers' misleading claims. Product certifications (Cradle to Cradle Certified®, Nordic Swan, EU Ecolabel), EcoVadis ratings and published sustainability reports are recognised as robust evidence. The source for this section is the ADA Cosmetics expert story "Hotel ESG Reporting in the UK", published on 22 July 2026; the rules described are British and do not apply in Romania.

The three pillars, with concrete actions for a hotel

Environmental (E). Measure energy and water per occupied room monthly. Separate waste by stream and ask suppliers for packaging data. Move from small portions to refillable dispenser systems, with 3 l or 5 l refills, where the room category allows. Document the evidence behind each environmental claim: certifications, test results, quantitative data, methodology and supplier documentation, as applicable. For generic claims such as "eco" or "green", the requirements are stricter: the trader must be able to demonstrate recognised excellent environmental performance relevant to the claim.

Social (S). Staff turnover, training hours, health and safety at work, accessibility for guests with reduced mobility, local suppliers. It is the pillar that is easiest to document and most often neglected.

Governance (G). Who is responsible for sustainability, which written policies exist (procurement, anti-corruption, data protection), how suppliers are vetted, how you report to the owner or operator. Without a named person, the data does not get collected.

Where the supply chain sits (Scope 3)

Scope 1 covers direct emissions (boilers, own fleet). Scope 2 covers emissions from purchased energy. Scope 3 covers the other indirect emissions in the value chain, structured by the GHG Protocol into 15 categories, including purchased goods and services, upstream transportation and distribution, waste generated in operations and certain travel associated with the business. Scope 3 can represent a significant share of a hotel's footprint, particularly through purchased goods and services.

Supplier selection has therefore become a reporting decision. A supplier with an annual sustainability report, an EcoVadis rating and product certifications delivers the data you need along with the goods. Without the supplier's primary data, the hotel can use estimates and secondary emission factors, but quality and traceability are generally better with product- or activity-specific data.

Hotel amenities touch packaging, waste, environmental claims and chain requirements all at once. A few documented reference points from ADA Cosmetics, the brand distributed in Romania by Concept Hotels. The documents that can support product claims may include environmental, social or sustainability certifications and labels; the effect of each depends on the certification scheme, the scope of the certificate and the claim used:

• the SmartCare dispenser is 100% mono-material; SmartCare Soft-Touch scored 18 out of 20 in Interzero's independent "Made for Recycling" assessment (September 2026);
• the patented Refillution refill system has been independently assessed by TÜV SÜD Industrie Service for hygienic design, controlled dosing and refilling, cleanability, technical documentation and product and batch traceability, against ISO 22716 (good manufacturing practice for cosmetics) and the traceability requirements of Regulation (EC) No 1223/2009; it delivers up to 95% less plastic waste than small portions, according to the manufacturer's methodology and calculation conditions, and one 10 l SmartCube replaces 34 dispenser bottles, with up to 30% less wasted liquid;
• the liquid cosmetics are Cradle to Cradle Certified® Full Scope Silver: certificate no. 12316, valid until 3 September 2028, with all five assessment categories at Silver level. Anyone can verify the certificate in the public Cradle to Cradle registry, together with the list of products covered. The certification can document certain product characteristics, within the limits of the certificate's scope;
• the product lines also carry other verifiable certifications: Nordic Swan Ecolabel, EU Ecolabel, ECOCERT Cosmos Organic, as well as FairTrade, which is a social and trade certification, not one of environmental performance;
• ADA Cosmetics holds the EcoVadis Gold medal 2024–2025 (top 5% of rated companies) and publishes an annual sustainability report; the 2025 edition has been available on the manufacturer's website since September 2026.

None of this writes the report for you, but it answers three questions you will be asked: what packaging you bring into the room, what happens to it after use, and what your claims are based on.

Who supplies the evidence: manufacturer, distributor, hotel

This is the question that arises as soon as you start asking for documents: are the manufacturer's data enough, or do you also need those of the local supplier? The answer is that the file is made up of three layers, each with its own main source.

The manufacturer issues everything product-related: the product carbon footprint, the certifications, material composition, recyclability, the list of excluded substances, the sustainability report. These documents can be used whoever you buy through, but each certification relates to the entity, product, range, factory or scope indicated in the certificate and must not be extended beyond it. The condition is that you quote the certificate number, its scope, its validity and the product code you bought, not the marketing page.

The distributor is the main source for the commercial-relationship layer and the local one. Your contract and your invoice are with them, and the operator's supplier questionnaires and rating requests are usually addressed to the entity the hotel has the contractual relationship with. An EcoVadis scorecard, for instance, is associated with the entity assessed and must not be presented as automatically representing another entity in the chain. The distributor is also the main source for the quantities delivered to your property in a given year (litres, units, kilograms of packaging by material), for packaging and for delivery conditions; without this data you are generally left with spend-based estimates. As regards packaging, the obligations fall on the economic operator that places the packaging or packaged products on the national market, and who that is in your chain is something to check contractually with the supplier. Likewise, transport from the local warehouse to the hotel belongs in Scope 3: delivery data and distances can allow a more precise calculation than an estimate based on spend alone.

The hotel adds what nobody else can know: consumption per occupied room, the room categories in which each system is used, its own targets and their timeline. It also keeps its own records: goods received, invoices, usage, waste records.

In short, the file has three levels:

• Level 1 — The manufacturer: certificates, technical data sheets, composition, packaging, footprint, ESG report, methodology.
• Level 2 — The supplier/importer: quantities delivered, invoices, packaging, transport, EPR status, local documents.
• Level 3 — The hotel: rooms, consumption, usage, occupancy, waste, energy, water, public communication.

In practice: ask your supplier for an annual file containing the manufacturer's certificates with numbers and validity dates, the quantities delivered to your property that year, documentation on meeting packaging obligations, to the extent these fall on the supplier or importer, an estimate of transport and their own company documents. With this set you move up from the spend-based method to the supplier-specific method recommended by the GHG Protocol, and the claims on your website and in your rooms are backed by a document rather than a brochure.

A practical six-step process

1. Set the perimeter and the owner. One hotel or the whole group; one person with a mandate and allocated time.
2. Run a simplified materiality analysis. List the topics that matter to the business and to stakeholders (guests, operator, bank, authorities). Energy, water, waste, people and the supply chain almost always come out on top.
3. Collect the data you already have. Utility invoices, waste collection contracts, HR records, supplier reports. A correct spreadsheet is enough for year one.
4. Calculate Scope 1 and 2, estimate Scope 3. Use the GHG Protocol; for Scope 3, start with the large categories (purchased goods, waste) and with suppliers that already have data.
5. Write to VSME. The voluntary standard is the relevant framework for undertakings that fall outside the CSRD obligation and, at the same time, the ceiling for requests covered by the value chain cap; a report in this format can reduce the fragmentation of data requests and provide a common set of information for corporate clients and financial institutions.
6. Check the claims and publish. Every environmental sentence on the website, in brochures and in rooms must have evidence in the report. Update annually.

Common mistakes

• Waiting for the legal obligation. Thresholds went up, but data requests came down the chain, through contracts.
• Starting with marketing. A report written for the website rather than for management contradicts real data at the first check.
• Ignoring in-room packaging. Small portions are visible waste, regulated from 2030 and the first thing an auditor notices.
• Using generic terms without evidence. "Eco", "green", "environmentally friendly", used as generic environmental claims without recognised excellent environmental performance relevant to the claim, may constitute banned practices from 27 September 2026, under GEO no. 18/2026; ANPC is the enforcement authority.
• Repeating the supplier's claims without the document behind them. A hotel that reproduces the claim in a commercial communication takes on the related legal risk and must be able to support it with evidence, even if the information comes from the manufacturer.
• Asking suppliers for everything. For requests made for CSRD reporting purposes, the value chain cap protects value-chain undertakings with up to 1,000 employees, for financial years starting on or after 1 January 2027. Even outside this protection, ask for the relevant data from the voluntary standard, not full reports.
• Not naming an owner. Without a person and a calendar, the exercise stops after year one.

How Concept Hotels can help

Since 2001, Concept Hotels has supplied hotels in Romania with ADA Cosmetics hotel amenities and dispenser systems, Aliseo room and bathroom accessories and Indel B minibars. For your ESG file we prepare, on request, an annual set per property: certifications for the products delivered, with numbers and validity dates, technical data sheets, the ADA sustainability report, the quantities delivered that year by product and by packaging material, documentation on meeting packaging obligations in Romania, to the extent these fall on the supplier or importer, and an estimate of the waste reduction from moving from small portions to refillable dispenser systems, based on your room count. We also add a page with public wordings supported by the available documentation and wordings that require additional evidence, so that the claims in your own materials hold up under scrutiny. Write to vanzari@concepthotels.ro.

Frequently asked questions

The information reflects EU legislation in force and the state of transposition in Romania as at 24 September 2026. The Romanian draft legislation mentioned does not constitute legislation in force until it is adopted and officially published. This article is for information only and does not constitute legal advice.

About the author

Dragoș Popescu

Founder, Concept Hotels

Dragoș Popescu founded Concept Hotels in 2001. Since 2004 the company has been ADA Cosmetics’ distributor for Romania and the Republic of Moldova, and it works directly with Indel B and Aliseo on equipping hotel bathrooms and guest rooms.

About Concept Hotels →

Sources (37)▾

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