EU crackdown on airline “green” claims: risks, compliance and opportunities for airlines

Background

In June 2023, the European Consumer Organisation alerted the European Commission to multiple airlines’ “green” claims and statements, asserted to contravene Directive 2005/29/EC (the Unfair Commercial Practices Directive), which prohibits unfair commercial practices and misleading actions and omissions.

On 6 November 2025 the European Commission announced that the Airlines had committed to change their practices. The focus is to end flight‑specific “CO₂‑neutral” or “offset” claims via add‑ons or alternative fuels, tighten the use of terms such as “sustainable aviation fuel” (SAF) with appropriate context, and raise transparency and evidential standards for environmental claims.

Airlines’ commitments include:

• Ceasing to suggest that a specific flight can be made “CO₂ neutral” or emissions can be “offset” by paying an add‑on, such as funding tree planting or purchasing credits at checkout.
• Avoiding vague “green” wording, icons or labels that could mislead customers.
• Using terms like SAF only with clear explanations of what they mean, including current availability, typical blend percentages and known limitations.
• Providing timelines and concrete actions when referring to future goals such as net zero, explaining which emissions are covered, and avoiding absolute claims without context.
• Avoiding unqualified “sustainable” slogans and messaging based on optional customer contributions, which are now considered high risk.

National Consumer authorities will monitor implementation and enforce the above commitments where necessary.

Comment

For the Airlines, this signals another challenge to ESG messaging under consumer protection legislation, following the UK’s Advertising Standards Agency’s decision in 2024 in relation to Virgin Atlantic’s Flight100.

The core message is that environmental claims should be specific, substantiated and transparent; grounded in real‑world operations and evidence. It should not be suggested that a single flight is “carbon neutral” merely because of an optional add‑on.

Airlines are at the sharp end. They bear the responsibility to comply with ESG regulations, which are complex, nuanced and replete with calculations, qualifications and assumptions. ICAO’s SAF guide alone runs to nearly 70 pages. Its bibliography contains 101 separate references.

Airlines need to convey ESG issues to the travelling public, but must do so in a concise, accessible and understandable way. Customer buy-in is key; both literally and metaphorically.

To succeed in compliant marketing, airlines will need to craft their materials to condense and simplify their messaging whilst remaining transparent and substantiated.

Evolving ESG: Advancing the roadmap for airlines

What can airlines do? While the CPC’s commitments currently apply to the Airlines, all airlines can proactively take steps to optimise their ESG materials.

Creating a strategic ESG roadmap can achieve this by:

• building the foundations to facilitate compliance with consumer protection regulations including training of marketing and e-commerce teams, and
• developing individualised frameworks for the form and content of both generalised marketing materials and specific ESG product sales, to balance legal compliance with marketing effectiveness.

The roadmap should include:

• Media selection to ensure airlines can substantiate claims effectively including via links and qualifying statements in visual and other recorded media.
• Re-framing carbon neutrality / offset language: Avoid any suggestion that an individual flight can be “CO₂ neutral” or “CO₂ compensated” through customer contributions, and re-frame in a broader context of overall net carbon reduction.
• Clear articulation of SAF: Contextualise SAF in terms of its current availability, typical blend levels, the basis of any lifecycle emissions figures, and known limits (e.g., supply constraints, cost, and infrastructure). Clarify when SAF purchases fund future supply rather than fuel used on the flight and avoid implying that SAF makes a flight emissions neutral.
• Linking “green” claims to real plans: Any net-zero or other forward-looking environmental statements should be linked to a credible plan, with interim milestones and clear scope. Ensure statements are relative rather than absolute, where appropriate.
• Robust record keeping which includes both internal and external evidence logs:
  • Internal evidence log: Keep the underlying data, calculations, sources, methodologies, assumptions, review notes and approval trail for each environmental claim made.
  • External evidence log: Prepare plain‑language summaries used in customer‑facing materials, explaining CO₂ calculations and comparisons, what is included or excluded, any ranges or uncertainties, and the basis for any figures.

Conclusion

By proactively developing an ESG marketing roadmap airlines can leverage their environmental credentials whilst minimising the risk of greenwashing claims.

Please do get in touch if you would like to discuss any of the points raised in the article.

The authors would like to acknowledge the contributions to this article by James Kennedy.

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