EmpCo and Tourism Sustainability Certification
Appendix to Update No. 1 | Public Version | Information confirmed as of 2 October 2026
Japan Sustainability Coordinator Association (JaSCA)
Related material | ECGT / EmpCo and Tourism Sustainability Certification Update No. 1 →
1. Purpose and Positioning of This Document
Following its interim review published on 25 September 2026 concerning Directive (EU) 2024/825 (EmpCo) and tourism sustainability certification, JaSCA has directly approached researchers, accreditation bodies, certification and tourism practitioners in Europe and Asia and has been advancing an international review of the issues raised.
This document is a public appendix summarising the principal responses received directly by JaSCA and the resulting progress of the review as of 2 October. It is not simply a survey of overseas practice. It shows how questions raised from Japan are now being examined through direct dialogue and factual clarification with researchers and institutional stakeholders overseas.
Individual comments and replies do not mean that the relevant person or organisation supports or endorses JaSCA’s analysis as a whole. Comments, expert referrals, review discussions and primary-source responses from institutions are therefore distinguished below.
2. Expansion of the International Review
| Stakeholders | Engagement to date | Significance for the review |
| European consumer-law and tourism researchers | Substantive comments, interest in citing the review, expert referrals, and discussions on academic / technical review | Testing JaSCA’s legal and structural analysis against international academic expertise |
| National Accreditation Bodies | Direct replies from DANAK and RvA to JaSCA | Primary-source clarification of the relationship between scheme evaluation and CB accreditation / external substantiation |
| Overseas tourism practitioners | Practical responses concerning scheme transition, OTAs and local implementation | Understanding responsibility and information-flow issues between global systems and local implementation |
3. Main Responses from Overseas Researchers and Experts
Professor Xavier Font | University of Surrey
[Substantive comments received; permission granted to use the summary]
Professor Font described JaSCA’s interim review as a strong summary of the current state of the art and considered that it was asking important questions. At the same time, he noted that there are currently few clear answers and that this uncertainty itself makes it difficult for organisations to respond proactively. He also observed that the issue extends beyond tourism and that the boundaries of what is acceptable may become clearer through future enforcement and case law.
Professor Font also offered personal professional observations concerning GSTC and Travalyst. JaSCA treats these separately from objective findings of fact. Professor Font expressly agreed to JaSCA’s proposed summary of his comments for use in its domestic communication.
Professor Hans-Wolfgang Micklitz | European University Institute
[Interest in citing JaSCA’s interim review]
Professor Micklitz contacted JaSCA to ask whether he could cite the interim review, and JaSCA replied that citation would be welcome. This does not constitute endorsement of the review or its legal analysis, but it is one indication that questions raised from Japan by JaSCA have entered the consideration of a European consumer-law scholar.
Professor Christian Twigg-Flesner | University of Warwick
[Referral to additional experts]
Professor Twigg-Flesner referred JaSCA to researchers with more specific expertise in the Directive and in EU consumer law and sustainable consumption. JaSCA has approached the referred experts and other researchers for academic / technical review, thereby expanding the network through which the analysis is being tested.
Other academic / technical review
JaSCA is in discussion with several overseas researchers regarding further review. Where substantive review results have not yet been received, no assessment is attributed to those researchers in this document. Confirmed results will be reflected in future updates where appropriate.
4. Responses from Overseas Tourism Practitioners
Overseas tourism practitioners have responded that the issues raised by JaSCA are important and require time to work through, while also noting the limited ability of local implementation bodies to change global certification systems or the internal processes of OTAs directly.
These responses do not establish the legal conformity of any particular scheme. They do, however, illustrate a central issue in the present review: responsibility and information are distributed across Scheme Owners, Certification Bodies, data intermediaries, OTAs and local implementation bodies.
5. New Primary Information from Accreditation Bodies
DANAK | Danish Accreditation Fund
[Direct reply to JaSCA on 2 October]
DANAK confirmed that it had evaluated the Green Key certification scheme and found it aligned with ISO/IEC 17065:2012 and suitable for accreditation. At the same time, DANAK confirmed that it has not accredited any Certification Body for certification according to the Green Key scheme. DANAK also explained that accreditation of a Certification Body for a specific scheme is a separate assessment from scheme evaluation.
RvA | Dutch Accreditation Council
[Direct reply to JaSCA on 2 October]
RvA confirmed that Audit Independer Group itself is not accredited by RvA.
Taken together, these direct replies from two National Accreditation Bodies provide primary-source clarification that evaluation of the Green Key scheme itself and the external basis for the competence and independence of the Certification Body actually carrying out certification need to be examined separately. JaSCA has reflected this clarification in Update No. 1.
6. What the International Review Is Showing
First, the questions raised by JaSCA are no longer confined to a domestic Japanese discussion. They have developed into direct exchanges with European researchers, National Accreditation Bodies and overseas tourism practitioners.
Second, the international responses do not provide one uniform “answer”. Significant uncertainty remains in the interpretation and practical implementation of EmpCo, and researchers have also pointed to the importance of future enforcement and case law.
Third, the review increasingly points beyond the conformity of individual schemes to the information chain: Scheme → Certification / Assurance → Data intermediary → Trader / OTA → Consumer, and to whether assurance information is preserved, updated and communicated throughout that chain.
Fourth, taking account of views from overseas experts, JaSCA will continue to test its analysis for errors, omissions and possible alternative legal interpretations, and will reflect the results in future Updates where appropriate.
7. Subsequent Overseas Responses
Travalyst [Interim review checked]
On 2 October, Travalyst informed JaSCA that it had reviewed the interim note published on 25 September and that there were no issues from its side. JaSCA does not treat this as endorsement of its analysis as a whole. It is recorded as confirmation that, at this stage, Travalyst has not requested corrections to the description of its role and public materials in the interim review.
Expedia Group [Substantive reply on sustainability certification display]
On 2 October, Expedia Group informed JaSCA that it displays more than 90 third-party sustainability certifications and more than 50 sustainability attributes and amenities, and that for lodging its certification data is guided by the Travalyst Certifications Initiative and supplied through BeCause. This provides primary-source confirmation from Expedia of part of the data flow: Certification scheme → Travalyst → BeCause → Expedia → Consumer.
However, Expedia’s reply did not directly address JaSCA’s questions as to whether Expedia itself conducts due diligence on EmpCo conformity, whether it examines assurance metadata such as the Certification Body, accreditation status and applicable standards, or whether the self-declaration basis of Travalyst status is communicated internally or to consumers. The data flow is therefore clearer, while the question of who performs assurance verification, and on what information, remains open.
8. JaSCA’s Role in International Review and Knowledge Return
Through this work, JaSCA is taking concrete questions arising in Japan’s tourism and certification market to overseas researchers, accreditation bodies, and certification and tourism practitioners, and bringing their replies, disagreements and primary-source information back into Japanese policy and practice.
JaSCA aims not merely to introduce overseas systems into Japan in one direction, but to strengthen its role in raising questions from Japan within international institutional and market discussions, and in connecting primary information and expert scrutiny back to practical implementation in Japan.
9. Next Steps
Seek a substantive response from FEE / Audit Independer on the standards and procedures supporting the competence and independence of the Certification Body in relation to Article 2(r)(iv).
Continue the academic / technical review now under way, distinguishing legal requirements, facts, expert interpretation and JaSCA’s policy proposals.
Continue reviewing responses from OTAs, data intermediaries and certification schemes, together with observations of consumer-facing display, to test end-to-end traceability of assurance information.
Where material new information emerges, publish additional updates and return the findings to stakeholders in Japan and overseas.
Note: This document is a public progress summary based on information confirmed as of 2 October 2026. Individual comments are reproduced or summarised only within the scope in which public use is appropriate, and are not generalised beyond the position of the relevant person or institution or treated as JaSCA’s legal conclusion.