The aviation sector is responsible for considerable CO2 emissions and additional non-CO2 warming effects. Given the current and projected growth of the sector, it is crucial to implement measures to reduce emissions. Many airlines take or are planning to take environmental measures and communicate about them. However, they should ensure their environmental claims do not mislead consumers.
Therefore, alongside 16 other consumer protection authorities, the Norwegian Consumer Authority has co-signed a joint letter to the aviation sector.
This letter urges airlines to review their commercial practices and ensure their environmental claims comply with applicable consumer protection laws. The letter explains why the issue is important, what environmental claims are, and how they should be substantiated.
Key Points of the Letter
The letter aims to raise standards and ensure traders comply with consumer protection laws by providing principles to assist traders when making environmental claims.
ICPEN makes the following recommendations and touches upon the following marketing principles regarding specific (problematic) practices in the aviation sector:
- Truthfulness and Accuracy: Environmental claims must be truthful, clear, and accurate. This also applies to product names, imagery, symbols, etc. (such as images of trees or leaves) which could be misleading.
- Evidence-Based Claims: Airlines should make environmental claims only when supported by scientifically robust and reliable evidence.
- Avoid Vague and General Claims: Claims such as “green” or “sustainable” should be avoided as they can mislead consumers about the real environmental impact.
- Significant Measures: Do not exaggerate the environmental benefits of minor improvements (e.g. elimination of single use plastics during in-flight service), but instead focus on significant measures to the environmental impact of the airline’s operations as a whole.
- Current Actions: Highlight specific measures already taken or currently being undertaken, rather than (uncertain) future aspirations such as “climate neutral”.
- Transparency in Carbon Offsetting: Clearly explain the impact, uncertainties and limitations of carbon offsetting schemes and avoid claims such as “Protect the environment – offset CO2”. It should be clear that carbon offsetting does not have a direct impact on the consumer’s flight, and as such does not eliminate the emissions from fuel combustion.
- Sustainable Aviation Fuel (SAF): SAF is seen by the aviation sector as a key method to reduce net carbon emissions. Claims about SAF should however be clear, accurate, and not misleading. Provide additional information to contextualize the extent of emissions reduction.
The full letter can be found here.
Legal Considerations and European common action against 20 airlines
This joint letter is based on internationally recognized principles for commercial communication to consumers as they exist in consumer protection laws applicable in most parts of the world. It is however important to notice that national laws may vary and that stricter rules than what the letter lays down could apply in certain jurisdictions. Within the EU/EEA for instance, environmental claims are assessed on the base of the Unfair Commercial Practices Directive(UCPD), its guidance and established case law. Last year, this directive was amended by the Directive on empowering consumers for the green transition which resulted in more explicit bans of certain claims to combat greenwashing. This Directive has to be transposed in national law by 27 March 2026.
The UCPD is also the legal basis used to identify potential greenwashing committed by 20 European airlines which resulted in the ongoing common action of the European Consumer Protection Cooperation Network (CPC) against those airlines . This action is currently led by the Norwegian Consumer Authority, the Belgian Economic Inspection, the Netherlands Authority for Consumers and Markets and the Spanish Directorate General of Consumer Affairs.