Campaigners, airline ads and the regulator

We’ve established that campaigners perceive airline advertising as promoting (as they see it) overconsumption, and planet-damaging growth, and that ultimately they want it banned or at least heavily restricted. They also don’t believe that the industry is serious about reaching net zero.

Instead they take the view that sustainability initiatives are tokenistic greenwashing, designed to hide the fact that the industry wants ever more people to fly, which in turn increases carbon emissions.

That’s the context in which they are increasingly taking airlines to either the national advertising regulator - or sometimes even to court.

Here are a few examples of that happening:

Probably the most high profile case involves Dutch airline KLM, as it generated headlines worldwide .

In summary, Dutch campaigners Fossielvrij NL (who we mentioned in the previous section), supported by ClientEarth and Reclame Fossielvrij are arguing that KLM’s Fly Responsibly campaign breaches the Dutch implementation of the EU’s Unfair Commercial Practices Directive “ by giving customers the false impression that its flights won’t worsen the climate emergency .”

In addition, the campaigners allege that

Avoiding the Greenwashing Trap carbon offsetting shouldn’t be used as an airline sustainability tool.

According to ClientEarth lawyer Johnny White:

“ When it comes to offsets claims, the law on misleading marketing needs to be enforced.

“ Trying to reassure customers that a small payment for tree planting or ‘sustainable’ fuel compensates for flight emissions undermines urgent climate action, is gravely misleading, and, the claim argues, is unlawful. ” ( see our separate report on carbon offsetting myths).

Finally, they allege that growth is inconsistent with sustainable aviation:

“ The legal action also calls out KLM’s promotion of its net zero pledge, arguing that the airline’s plans for continued growth are squarely inconsistent with its claims that the company and the wider industry is taking action that aligns with climate goals. ”

This case comes as The Dutch Advertising Code Committee (RCC) already ruled that advertising copy used by KLM such as “Neutralise your impact on the environment with the CO2ZERO service” is misleading.

Meanwhile in Austria, Austrian Airlines was successfully taken to the national ad regulator following a campaign where Austrian Airlines said you could fly “CO2 neutral” from Vienna to Venice for the Biennale Festival.

The promotion involved offsetting your flight with SAF, and receiving free entry to the Biennale, along with public transport tickets in both Venice and Vienna.

According to Austrian Airlines CCO Michael Trestl : “ This fall, our environmentally conscious and art-savvy passengers can enjoy the Biennale Arte 2022 comfortably and sustainably! ”

The complaint made by an academic and climate change activist to the Austrian advertising regulator (English original version here), said that Austrian’s SAF comes from biofuels, which aren’t 100% carbon neutral, instead there is likely to be an 80% reduction.

The complaint went on to say:

“The consumer doesn’t understand a) what SAF is; b) what the net saving potential of SAF is; and c) what 100% SAF means.

Therefore, the average consumer might easily think that he/she is able to ‘fix’ aviation’s climate problem by purchasing SAF.

“This is what the message ‘fly carbon neutral already today’ suggests. It’s deeply misleading. In fact, it’s clever accounting that simply isn’t good enough to justify the use of claims such as ‘fly carbon neutral today’.”

The ad regulator agreed with the point that an 80% reduction was not carbon neutral flying. The regulator further criticised Austrian for using terms “not familiar to the average consumer, not explained in detail and could therefore be misunderstood”.

Austrian was asked to “be more sensitive in its design and more precise in its wording” of ads.

In response, Austrian said it took note of the findings, but said it doesn’t claim that SAF eliminates all climate related problems.

Our take on this is that the Austrian advertising regulator is right about one thing: Most consumers almost certainly have no idea what SAF is.

Yet, the way a lot of SAF is made is actually pretty interesting, and would capture consumers’ imaginations.

For example, you can now turn household trash into SAF ( Fulcrum BioEnergy does this). You can even produce solar jet fuel, see Synhelion , which has worked with Austrian’s parent, the Lufthansa Group.

The need to add more storytelling into sustainability advertising, and the role it can play in combating accusations of greenwashing, is something we’ll look at in the next section.

Why do they do it?

So why are climate groups increasingly going down this road when it comes to airline sustainability campaigns:

1 - It gets publicity

The first objective is always to shift the narrative. And as we’ve shown, that narrative is that flying is a social ill, flights should be capped and so airline marketing should be restricted.

Even if unsuccessful, simply proceeding with an action like this inevitably generates a lot of press coverage.

2 - The industry doesn’t have credibility

As we’ve said, activists simply don’t believe that the industry is serious about decarbonisation, or that it’s even possible in the short to medium term.

They also point to countless missed sustainability targets or environmental initiatives that came to nothing.

For example, Climate group ‘Possible’, published a report claiming that airlines missed or delayed 49/50 climate targets set since 2000.

To take one example in the report, Possible claims that Virgin Atlantic, in 2010 said that 10% of its fuel would be biofuels by 2020. Possible says that this target wasn’t mentioned again, but that in 2021 Virgin said that ‘alternative fuel’ use would now constitute 10% by 2030.

Clearly, a 10% biofuel target by 2020 was to say the least highly optimistic, verging on the almost impossible, given the current SAF scarcity.

However, the fact is that airlines have made eye-catching and PR worthy announcements in the past with no real plan about how to turn them into reality.

3 - A lot of campaigns can be challenged

Sometimes phrases like ‘carbon neutral’ or ‘CO2 neutral’ are thrown around. These can be, and often are, challenged.

And as the Austrian ad regulator said with the Austrian Airlines case, most consumers have no idea what things like ‘SAF’ really mean.