The Advertising Standards Authority is cracking down on environmental claims and even language widely in use may need qualifying. Ian Taylor reports
A Virgin Atlantic advert which hailed the use of “100% sustainable aviation fuel” on a one-off Heathrow-to-New York flight last November fell foul of Advertising Standards Authority (ASA) rules this month.
It was the latest in a series of rulings highlighting just how difficult it can be for travel companies to refer to efforts to reduce CO2 emissions if selling overseas holidays and specifically called into question use of the term ‘sustainable aviation fuel’ (SAF).
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A Virgin Atlantic radio advert broadcast a few days ahead of the November flight noted it would make the carrier “the world’s first commercial airline to fly transatlantic on 100% sustainable aviation fuel”.
The ASA investigated following several complaints.
Defending the advert, Virgin Atlantic pointed out ‘100% sustainable aviation fuel’ was the term used by the UK Department for Transport to refer to the project – a competition to operate the first solely SAF-fuelled flight across the Atlantic – and meant the flight was exclusively powered by SAF.
It noted the term ‘sustainable aviation fuel’ is used “universally by governments, regulators, industry bodies, the International Civil Aviation Organisation (ICAO), fuel companies, airlines, academia, aircraft and engine manufacturers and mainstream media”.
The airline also noted a consumer survey it ran on reactions to the advert found a majority of respondents understood the 100% claim related to the proportion of SAF used.
However, the ASA was not impressed.
It considered “a significant proportion” of consumers would understand the claim to mean “the fuel used was 100% sustainable” and argued: “Most consumers were unlikely to be aware of the extent to which fuels described as SAF still had negative environmental impacts.”
In the ASA’s view, the survey responses “confirmed the limited knowledge and lack of clarity among consumers about the environmental impact of SAF”.
It noted 11% of them “understood [from the ad] that SAF had zero environmental impact” and 30% believed a statement put to them separately that SAF had “zero impact” on the environment.
The ASA also noted SAF “produced significant emissions over its lifecycle [including] significant CO2, nitrous oxide and other climate-impact emissions [and] its production was not without other potentially negative environmental impacts”.
It concluded “the unqualified claim ‘100% sustainable aviation fuel’ was misleading” and adverts referring to SAF should include “qualifying information which explained the environmental impact”.
This would be in line with demands from aviation environmental organisations, such as the Aviation Environment Federation (AEF), which have questioned use of the term ‘sustainable aviation fuel’.
In April, AEF policy director Cait Hewitt pointed out in regard to SAF: “These fuels release as much CO2 as kerosene when burned.”
Misleading impression
The ASA ruling on Virgin Atlantic’s advert followed a ruling in July against Hurtigruten Expeditions over a digital newspaper advert which described Hurtigruten as “leaders in sustainable expeditions” and offered “free flights to Svalbard”.
The authority ruled this “gave a misleading impression, [as] sustainable expeditions would be understood as including travel to and from the destination”.
It noted air travel “such as that required to take a Hurtigruten Exhibitions cruise” produces “high levels of both CO2 and non-CO2 emissions” which make “a substantial contribution to climate change”.
Also in July, the ASA banned adverts promoting Luton Airport’s expansion for omitting “material information” about the environmental impact of the plans.
A magazine advert and poster placed by airport owner Luton Rising claimed: “If we miss our environmental limits, our expansion will be stopped in its tracks.”
The ASA judged the advertised claims “failed to clarify that carbon emissions from additional air traffic were excluded” from the environmental limits, noting unqualified claims “could mislead if they omit significant information”.
It concluded: “Excluding air traffic emissions was material information that was likely to affect people’s understanding of the ads’ overall message.”
Last year, the ASA upheld a complaint against an Intrepid Travel advert on the London Underground which featured the Giza Pyramids in Egypt and referred to ‘People and planet-friendly small group adventures”.
The ASA ruled the advert “misleadingly minimised the impact of Intrepid Travel’s holidays . . . [because] it would be necessary to travel, in most cases by flying”.
It argued: “Air travel produced high levels of both CO2 and non-CO2 emissions, which made a substantial contribution to climate change, and those emissions were not accounted for by Intrepid Travel.”
Also in 2023, the ASA found Etihad Airways made misleading claims in Facebook adverts suggesting the carrier was taking “a louder, bolder approach to sustainable aviation”.
Again, it noted flying produces “high levels of CO2 and non-CO2 emissions, making a substantial contribution to climate change” which had to be acknowledged if making an “absolute” claim.
ASA operations manager Justine Grimley outlined the authority’s approach at an Abta Travel Regulations Conference last November, saying: “It is important claims are based on reality and people can understand what you’re talking about, [when] people’s understanding is not that high.”
She explained “absolute claims have to be supported by evidence” and noted: “To date we’ve not been presented with any evidence on a lifecycle claim that we’ve accepted. The bar is very high.”
If advertising an overseas holiday, she said, the ASA would “require a company take account of the flights even if they don’t sell them”.
Grimley warned that describing a trip as ‘environmentally friendly’ would be “very difficult to substantiate”.
Industry lawyer Alex Padfield, director of Hexstalls Law, told the conference: “The more you claim, the higher the level of substantiation needs to be. You must not omit anything.
“If you say something that leads a customer to make a choice, it could be an offence.”
Explore Worldwide managing director Michael Edwards noted this week, in a comment for Travel Weekly: “We’re all learning how to get the messaging right.”
In light of that, it is worth noting the ASA has offered free advice to businesses and says it will review any advert in advance of release if given at least 24 hours’ notice.