Virgin Atlantic has been ordered to ensure future adverts which refer to the use of sustainable aviation fuel (SAF) includes qualifying information explaining its environmental impact.
The ruling came as the advertising watchdog banned a radio advert in which the airline hailed the use of “100% sustainable aviation fuel” on a one-off ‘Flight 100’ to New York from Heathrow last November.
The transatlantic flight was operated after the airline won a Department form Transport competition to “support industry to achieve the first net zero transatlantic flight on an aircraft using 100% sustainable aviation fuel within one year”.
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Five people complained to the Advertising Standards Authority (ASA) that using the “100% SAF” claim gave a misleading impression of the fuel’s environmental impact and questioned whether it could be substantiated.
Virgin Atlantic confirmed that SAF produced the same level of CO2 emissions during flight as traditional jet fuel.
However, because SAF utilised carbon that had recently been captured from the atmosphere, “the CO2 savings were relative to a net increase in atmospheric carbon that would have been emitted had fossil fuels been dug up and used”.
Additional savings could also be realised through a reduction in lifecycle emissions from extraction, processing, manufacturing, transportation of the fuel, and through improving operational efficiencies, the carrier told the ASA.
Overall, Flight 100 had delivered a lifecycle CO2 emissions saving of 64%, Virgin Atlantic pointed out.
“The deployment of sustainable aviation fuel therefore represented a significant reduction in emissions,” it told the ASA.
The flight’s fuel also produced around 40% lower non-CO2 emissions – particulates such as water, sulphur oxides, soot and nitrous oxides – compared to fossil derived fuels.
The airline referred to a consumer survey commissioned in response to the complaints in which 68% of people said “they understood from the ad that sustainable aviation fuel was better for the environment than traditional jet fuel, but that it was not without any adverse impact”.
A further survey conducted since receiving notification from the ASA identified that sustainability factors “influenced only around 1.5%” of consumer’s overall choice about long-haul airlines.
Virgin Atlantic emphasised that the ad’s wording “… become the world’s first commercial airline to fly transatlantic, on 100% sustainable aviation fuel” mirrored the terms used by the DfT in its competition invitation.
The airline said it believed consumers would understand the term “100% sustainable aviation fuel” in the context of the ad to be a reference to a type of fuel which was made from sustainable sources, rather than being fossil fuel based, and “which reduced but did not necessarily completely eliminate greenhouse gases”.
Virgin Atlantic told the ASA it did not think listeners would understand the ad to mean that the fuel used for Flight 100 was derived from completely sustainable sources, did not generate CO2 or other emissions that had an adverse environmental impact during use, and that over its full lifecycle had no adverse environmental impacts.
“The ad did not claim that the fuel was 100% sustainable, nor did it give a misleading impression about the absolute or relative environmental nature, impact or credentials of sustainable aviation fuel (as compared to other aviation fuel). Rather, it factually described how the flight was powered exclusively by sustainable aviation fuel,” the carrier pointed out.
Virgin Atlantic also pointed out that the term “sustainable aviation fuel” was used universally by governments, regulators, industry bodies, fuel companies, the International Civil Aviation Organisation (ICAO), airlines, academia, aircraft and engine manufacturers and mainstream media.
“The ad therefore accurately referred to the type of fuel by its universally recognised and used definition,” the airline said. “The term was used for synthetic aviation fuel that was not derived from fossil fuel. It encompassed fuel made from waste or renewable feedstocks. There were various feedstock sources and technology pathways that could be deployed to produce it.”
But, upholding the complaints, the ASA “considered that while many listeners would understand from the ad that Flight 100 had, uniquely, flown transatlantic using only sustainable aviation fuel, a significant proportion would understand the claim ‘100% sustainable aviation fuel’ to mean that the fuel used was 100% sustainable.”
The ASA added: “We acknowledged the ad specifically highlighted Flight 100, which was a non-commercial flight for which listeners could not purchase tickets.
“However, it had the effect of building the overall impression that Virgin Atlantic was committed to taking on a challenging, pioneering and continuing role in working towards reducing the environmental impact of aviation.
“We considered many listeners would be interested in seeking out airlines that were taking such action. The ad specifically highlighted the use of sustainable aviation fuel in Flight 100; a method by which a reduction in environmental impact could be achieved.
“We therefore considered that information about its limitations in that regard constituted material information that would have an impact on the transactional decisions of those listeners.
“We therefore concluded that the unqualified claim ‘100% sustainable aviation fuel’ was misleading.
“We told Virgin Atlantic to ensure that future ads which referred to the use of sustainable aviation fuel included qualifying information which explained the environmental impact of the fuel.”
The airline said it was disappointed with the ruling but it remained committed to leading industry efforts to achieve net zero CO2 emissions by 2025.