Lufthansa's green claim grounded by the ASA

It's not been a good week for green claims and airlines. Today's publication of a decision by the UK's Advertising Standards Authority to ban a poster ad published by Lufthansa comes on the back of other news that pours cold water on environmental claims by airlines.

First, the poster. The artwork comprises an image showing the top half of an airplane, with the bottom half being planet earth. The copy states, "Connecting the world. Protecting its future." and is accompanied #MakeChangeFly and makechangefly.com. The poster is proof, if any were needed, that accusations that the Germans lack a sense of humour are unfounded, because they must have been having a laugh. 

Once again, we see that the ASA is resisting the turbulence that buffets it off course. Instead, it launched its own investigation, pre-empting the complaints that would surely have been received from lobby groups and concerned citizens. By launching an investigation on its own initiative, the ASA avoided any delay in the landing of the Council adjudication, bringing the media schedule for Lufthansa's poster to an early end.

Lufthansa's response to the ASA' challenge was about as nourishing as an airline meal. They argued that neither claim in the body copy, nor the image of the airplane and globe, would be interpreted as an absolute claim. They also argued that average consumer would not understand their claims to mean that their services do not harm the environment. Ah! German humour! Their defence largely turned on their intention to drive traffic to their website, where consumers could learn about "the environmental issues related to flying and the steps Lufthansa had taken to address them." They said that their explanation and qualification for their claims was on the website at makechangefly.com - which appears in the ad, although without any prompt to go there for more information.

Once the on the website, users would apparently find warm words (but not too warm) about the social and economic importance of aviation, all of which sound rather self-evident, as does their acknowledgement that aviation emits CO2. The website goes on to state some of the steps being taken to address climate change, such as modernising their fleet and buying 'Sustainable Aviation Fuel'. The nub of their defence was that the website provided the context and substantiation for the ad, as well as the qualifications which would mean that consumers would not be misled. 

The ad traffic controllers at the ASA were not impressed, and Lufthansa were denied permission to take off. The two claims "connecting the world" and "protecting its future", in conjunction with the image of the globe, created a high-level claim that Lufthansa was already taking steps to protect the environment. 

Furthermore, the claim "protecting its future" was not qualified in any way, such as by the airline's aspiration to be carbon neutral by 2050 and to cut carbon emissions by 50% by 2030. Without these qualifications, consumers would be likely to interpret this claim as meaning that Lufthansa "had already taken significant mitigating steps to ensure that the net environmental impact of their business was not harmful." In fact, aviation continues to make a substantial contribution to climate change and their initiatives were not targeted to deliver results for many years to come. 

In conclusion, the ASA applied its usual reasoning, and found (a) the basis of the claim was unclear and (b) the claim had not been adequately substantiated. Consequently, the ad breached the Code. Lufthansa were told to have 'robust' substantiation for future claims. This casual use of language in adjudications is frustrating and confusing, as it leads to uncertainty about the standards required for substantiation by using language that is not in the CAP Code itself. When is substantiation 'robust' rather than 'delicate'? 

There is also an interesting line in the adjudication that, "We also understood that there were currently no environmental initiatives or commercially viable technologies in the aviation industry which would substantiate the absolute green claim “PROTECTING ITS FUTURE”, as we considered consumers would interpret it." Although it is not called out, this might be a reference to 'Sustainable Aviation Fuel'. Although it is technologically possible to produce aviation fuel from waste, it is only happening in tiny quantities at present.

This leads us on to the second news item that will keep airlines green claims grounded. Yesterday (28th February 2023), The Royal Society published a report into Net Zero Aviation Fuels. There is still a long way to go before a solution to decarbonising air travel is commercially available on a wide scale.

In the meantime, airlines need to be very careful about making unqualified or high-altitude environmental claims, as this risks pouring fuel on the flames of the environmental debate. And that is unlikely to end well for an airline.