In addition, current and upcoming legislation, with ESG considerations at its core, is increasingly forcing hospitality businesses to reshape their behaviours and processes. Here I outline just some of the areas that hospitality businesses are required to comply with.
 

1. Supply chain and reporting

More than ever, British hospitality businesses must have oversight over their entire supply chains. In addition to robust due diligence conducted to avoid falling foul of relevant regulations regarding sourcing of goods, businesses face a continuing obligation to monitor supply chains to comply with growing ESG reporting requirements. 

Close ties between UK and EU food systems mean that certain incoming EU directives, such as its Deforestation Regulation, are likely to have an impact on UK hospitality businesses’ supply chains. 
 

2. Energy

Regulations promoting energy efficiency are relevant for all businesses in the UK, but particularly for those operating from physical premises. Hospitality businesses must be conscious of their statutory obligations to maximise energy efficiency and reduce carbon emissions and can consider tools such as green leases and corporate power purchase agreements to satisfy these aims. 

Physical premises also allow for the implementation of innovative on-site or near-site energy solutions such as distributed generation from renewable sources (e.g. solar power), distributed energy storage for use during peak periods or demand response (i.e. controlling energy usage during peak demands and high pricing periods). 
 

3. Packaging and waste 

A focus at the UK and EU level on the ‘circular economy’ is putting pressure on both packaging producers and hospitality businesses to switch to packaging that is easier to recycle and to think carefully about producing less packaging overall. 

The disposal and management of packaging and other waste is increasingly the responsibility of those who produce it, with legislation introducing ‘base fees’ payable by producers to local authorities for different categories of waste packaging material. 
 

4. Green claims

Hospitality businesses seeking to capitalise on the growing number of sustainability-minded consumers whilst highlighting their own green credentials must be aware of the strict prohibition on misleading ‘green claims’. Phrases, but also imagery and colour patterns, can be considered misleading if they are not supported by adequate evidence. “Green” trademarks and logos will also come under further scrutiny over the next twelve months. As the environmentally conscious consumer group continues to expand, so too must awareness of how marketing can be used to target this group without falling foul of regulation.  

The consequences of getting it wrong range from accusations of ‘greenwashing’ and being named and shamed by the Advertisement Standards Authority, to the Competition and Markets Authority issuing fines of up to 10% of global revenue. 
 

5. A final greener mile

Urban last-mile delivery is key to the hospitality sector, and while it is an important revenue driver, it is also a significant contributor of carbon emissions. Creating and implementing an eco-friendly delivery strategy can help hospitality organisations satisfy customer demand while meeting ESG objectives. Whether by utilising green delivery slots, optimising delivery routes or switching to an eco-friendly/conscious fuel and vehicles, hospitality businesses have a number of options at their disposal to reduce emissions in this final stage. 
 

How Bird & Bird can help 

Bird & Bird’s UK and EU-based teams have extensive experience helping businesses audit their supply chains and regularly support hospitality businesses to simplify, identify, assess and address ESG regulations. We advise on a range of regulatory compliance issues, from emissions reporting to green claims. 

We can also help you create a comprehensive ESG approach that meets your specific energy needs, whether that be via offsite and/or onsite solutions. Our experience working on a broad spectrum of commercial contracts at the crossroads between the hospitality and energy sectors ensures that we deliver practical and effective outcomes. 

For more information please contact Graeme Payne and Emma Green, both of whom will be attending the Planet Peach sustainability summit on 4 March 2025.

Bird & Bird is a Peach 20/20 and Planet Peach partner.