Avoiding the Greenwashing Trap: A Guide for Airlines and Airports

Avoiding the Greenwashing Trap

A guide for airlines and airports

Big Tobacco Yesterday, Big Oil Today, Big Aviation Tomorrow?

Two and a half years ago , we reported on the negative reaction oil companies were getting in response to commercial sponsorships where environmental groups tried to make those links socially unacceptable.

We predicted that at the current pace, airlines and the global aviation industry would soon be placed in the same reputational pot.

Fast forward to September 2022, and many of the groups such as “Clean Creatives” , which formerly had oil companies in their sights, organised an anti-aviation guerilla advertising campaign in 15 European cities.

The crux of their argument was that airline sustainability campaigns are nothing more than ‘greenwashing’, and that airline advertising should even be banned. This follows a number of high profile court cases across Europe, where environmental campaign groups have been taking airlines to court for what they say are misleading environmental claims.

Occasionally, the reaction to this has been to assume a defensive crouch, where it’s seen as safer to say nothing.

We think that’s the wrong approach. For one thing these groups are going nowhere and their arguments need to be engaged with. More to the point, we do think it’s possible to tell your sustainability story in a compelling way without being accused of greenwashing.

In this report, we’ll look at how and why climate activists are starting to target airlines, what their main claims are and how airlines are often getting it wrong.

With a lot of positive work actually going on in aviation’s journey to net zero, we’ll then suggest a way forward.

Finally, if after reading this report you want to go one stage further, we’re holding a limited number of sustainability communications master-classes next year. You’ll find more details of this on page X.

Dirk Singer Head of Sustainability, SimpliFlying dirk@simpliflying.com

September’s anti-airline ad campaign

In September, climate change activists took over billboards in 15 European cities.

Their target? Europe’s airlines. Their aim? To draw attention to what they see as aviation’s growing share of carbon emissions, and to continue pushing the narrative, started by the ‘flight shaming’ movement, that flying is selfish and a social ill.

As far as they are concerned, airlines are now part of the wider fossil fuel industry just like oil giants such as Shell, BP or Exxon-Mobil. And so using the hashtag #BanFossilAds, they also called for all fossil fuel company advertising to be treated like tobacco advertising.

In addition, they wanted to ‘shame’ advertising agencies with aviation clients.

According to Tona Merriman from Brandalism: “The allure and glamour of high carbon lifestyles such as frequent flying has been purposefully crafted by the advertising industry and shows no signs of relenting – despite one of the hottest summers on record.

“Advertising agencies such as Ogilvy, VCCP, Dentsu, DDB Munchen need to consider their role in driving up emissions for airlines they work for such as British Airways, Easyjet, KLM and Lufthansa. We call on employees in those firms to refuse work for high carbon clients.”

Here are a few examples of their work:

“Fly responsibly towards a more responsible future” , read this bus stop ad in Nantes, France, with a picture of a plane circling over a burning planet. The slogan made reference to KLM’s ‘ Fly Responsibly ’ campaign.

This poster in London was done in the style of a British Airways ad with the headline, “We’re turning business class green with the world’s first on-board golf course.”

The ad referenced the fact that business class is responsible for a higher per passenger share of emissions than economy.

It then made a joke at BA’s expense in talking about each on-board golf course coming with a “biodegradable golf ball.”

Meanwhile an anti-Lufthansa ad called out LH’s advertising agency DDB, and turned Lufthansa’s marketing slogan, #SayYesToTheWorld into #SayYesToTheEndOfTheWorld.

The ad also seemed to reference Lufthansa’s carbon offsetting scheme, Compensaid, with the tagline “we distract you with pictures of trees while we fry the planet.”

Other airlines targeted included Air France, easyJet, ITA Airways, and Ryanair, while there were also billboards objecting to proposed airport expansion in Liege (Belgium) and Bristol (UK).

What do these campaigns tell us?

Reputationally, campaigners perceive there to be little difference between oil giants and airlines

As they see it, it is all part of the wider fossil fuel industry contributing to global warming

Direct action of the kind oil companies have been subjected to for a few years now, will increasingly be targeted towards the aviation industry

Climate change activists simply don’t believe that the aviation industry is serious in wanting to decarbonise, and in fact don’t even think there’s a viable route to doing so, other than stopping people from flying. This is an important point, and one we will come back to.

The call for airline ads to be treated like alcohol or tobacco advertising

safe future: Are airlines sending the wrong message? ”

The paper breaks down airline marketing and says that it broadly follows three themes:

• “Adventure and discovery” - check out these great destinations

• “Privilege” - take a look at our amazing lounges, service. Travel confers status

• “Urgency” - buy now in our sale!

As a result of this, the authors conclude that “it is evident that the marketing efforts of airlines included in our analyses are designed to drive excessive demand and encourage over-consumption.”

As we mentioned in the previous section, the groups who subverted airline ads in September want airline advertising banned. It’s obviously an idea that as yet isn’t mainstream. However, we’re starting to see it filter from activists into academia and the media.

For example, University of Surrey academics

Paul Hanna and Scott Cohen released a paper in the Journal of Travel Research, titled “ Reconfiguring aviation for a climate-

While acknowledging some sustainability focused campaigns, such as KLM’s Fly Responsibly, the authors go on to say that “nascent evidence of green shoots in some airline marketing campaigns is belated and inadequate.”

Then comes their conclusion - “policy interventions will be required to regulate airline marketing, as arises in relation to other consumer products (e.g. tobacco and alcohol) that have damaging public health outcomes.”

And the academics who authored this report are by no means isolated voices. For instance:

Andrew Simms, co-director of the New Weather Institute and assistant director of Scientists for Global Responsibility, wrote a piece in the very mainstream New Scientist magazine, titled, “it worked with cigarettes. Let’s ban ads for climate-wrecking products.”

Similarly, Greenpeace Netherlands commissioned a report by DeSmog to look at airline advertising.

The report claims that: 90% of airline ads made no mention of sustainability (that could easily be turned around. 1/10 of airline advertising mentioning sustainability is actually significant)

The report mentions Brussels Airlines, Air France and SAS as airlines that did run advertising campaigns with sustainability themes.

SAS in particular,”stood out as the one firm that dedicated the most significant number of adverts to the environment – focusing on offsetting, the use of “ sustainable aviation fuels” (SAFs) and electric planes in more than a quarter of its adverts. ”

However, the report then dismisses these initiatives out of hand. “ Campaign group the Aviation Environment Federation have

labelled the green initiatives marketed by airlines as “uncertain” or “unrealistic” solutions. ”

Policy markers are starting to react

And starting at a local Government level, policy makers are responding.

In late August, the City of Sydney voted to no longer accept fossil fuel advertising or sponsorships, for example for city wide events such as the New Year’s Eve Fireworks.

Though for now the resolution seems to cover only oil and gas companies, as we’ve shown, aviation is very much starting to be perceived to be in the same bracket.

Amsterdam is likewise banning fossil fuel ads from its Metro - and here it does include flights.

According to Radjen van Wilsem, the chief executive officer of CS Digital Media, the company that places ads in the metro:

source: DeSmog

“We don’t tell you you can fly to Barcelona for 19 euros. We don’t do that anymore.”

From the perspective of Dutch campaigners, this is a good step, but it doesn’t go far enough:

“We want a national ban” , says George Ongkiehong from Reclame Fossielvrij, quoted in ‘The World.’ “We are striving toward a tobacco-style law.”

Reclame Fossielvrij has also published a list of worldwide initiatives to ban fossil fuel ads.

Campaigners, airline ads and the regulator

We’ve established that campaigners perceive airline advertising as promoting (as they see it) overconsumption, and planet-damaging growth, and that ultimately they want it banned or at least heavily restricted. They also don’t believe that the industry is serious about reaching net zero.

Instead they take the view that sustainability initiatives are tokenistic greenwashing, designed to hide the fact that the industry wants ever more people to fly, which in turn increases carbon emissions.

That’s the context in which they are increasingly taking airlines to either the national advertising regulator - or sometimes even to court.

Here are a few examples of that happening:

Probably the most high profile case involves Dutch airline KLM, as it generated headlines worldwide .

In summary, Dutch campaigners Fossielvrij NL (who we mentioned in the previous section), supported by ClientEarth and Reclame Fossielvrij are arguing that KLM’s Fly Responsibly campaign breaches the Dutch implementation of the EU’s Unfair Commercial Practices Directive “ by giving customers the false impression that its flights won’t worsen the climate emergency .”

In addition, the campaigners allege that

Avoiding the Greenwashing Trap

carbon offsetting shouldn’t be used as an airline sustainability tool.

According to ClientEarth lawyer Johnny White:

“ When it comes to offsets claims, the law on misleading marketing needs to be enforced.

“ Trying to reassure customers that a small payment for tree planting or ‘sustainable’ fuel compensates for flight emissions undermines urgent climate action, is gravely misleading, and, the claim argues, is unlawful. ” ( see our separate report on carbon offsetting myths).

Finally, they allege that growth is inconsistent with sustainable aviation:

“ The legal action also calls out KLM’s promotion of its net zero pledge, arguing that the airline’s plans for continued growth are squarely inconsistent with its claims that the company and the wider industry is taking action that aligns with climate goals. ”

This case comes as The Dutch Advertising Code Committee (RCC) already ruled that advertising copy used by KLM such as “Neutralise your impact on the environment with the CO2ZERO service” is misleading.

Meanwhile in Austria, Austrian Airlines was successfully taken to the national ad regulator following a campaign where Austrian Airlines said you could fly “CO2 neutral” from Vienna to Venice for the Biennale Festival.

The promotion involved offsetting your flight with SAF, and receiving free entry to the Biennale, along with public transport tickets in both Venice and Vienna.

According to Austrian Airlines CCO Michael Trestl : “ This fall, our environmentally conscious and art-savvy passengers can enjoy the Biennale Arte 2022 comfortably and sustainably! ”

The complaint made by an academic and climate change activist to the Austrian advertising regulator (English original version here), said that Austrian’s SAF comes from biofuels, which aren’t 100% carbon neutral, instead there is likely to be an 80% reduction.

The complaint went on to say:

“The consumer doesn’t understand a) what SAF is; b) what the net saving potential of SAF is; and c) what 100% SAF means.

Therefore, the average consumer might easily think that he/she is able to ‘fix’ aviation’s climate problem by purchasing SAF.

“This is what the message ‘fly carbon neutral already today’ suggests. It’s deeply misleading. In fact, it’s clever accounting that simply isn’t good enough to justify the use of claims such as ‘fly carbon neutral today’.”

The ad regulator agreed with the point that an 80% reduction was not carbon neutral flying. The regulator further criticised Austrian for using terms “not familiar to the average consumer, not explained in detail and could therefore be misunderstood”.

Austrian was asked to “be more sensitive in its design and more precise in its wording” of ads.

In response, Austrian said it took note of the findings, but said it doesn’t claim that SAF eliminates all climate related problems.

Our take on this is that the Austrian advertising regulator is right about one thing: Most consumers almost certainly have no idea what SAF is.

Yet, the way a lot of SAF is made is actually

pretty interesting, and would capture consumers’ imaginations.

For example, you can now turn household trash into SAF ( Fulcrum BioEnergy does this). You can even produce solar jet fuel, see Synhelion , which has worked with Austrian’s parent, the Lufthansa Group.

The need to add more storytelling into sustainability advertising, and the role it can play in combating accusations of greenwashing, is something we’ll look at in the next section.

Why do they do it?

So why are climate groups increasingly going down this road when it comes to airline sustainability campaigns:

1 - It gets publicity

The first objective is always to shift the narrative. And as we’ve shown, that narrative is that flying is a social ill, flights should be capped and so airline marketing should be restricted.

Even if unsuccessful, simply proceeding with an action like this inevitably generates a lot of press coverage.

2 - The industry doesn’t have credibility

As we’ve said, activists simply don’t believe that the industry is serious about decarbonisation, or that it’s even possible in the short to medium term.

They also point to countless missed sustainability targets or environmental initiatives that came to nothing.

For example, Climate group ‘Possible’, published a report claiming that airlines missed or delayed 49/50 climate targets set since 2000.

To take one example in the report, Possible claims that Virgin Atlantic, in 2010 said that 10% of its fuel would be biofuels by 2020. Possible says that this target wasn’t mentioned again, but that in 2021 Virgin said that ‘alternative fuel’ use would now constitute 10% by 2030.

Clearly, a 10% biofuel target by 2020 was to say the least highly optimistic, verging on the almost impossible, given the current SAF scarcity.

However, the fact is that airlines have made eye-catching and PR worthy announcements in the past with no real plan about how to turn them into reality.

3 - A lot of campaigns can be challenged

Sometimes phrases like ‘carbon neutral’ or ‘CO2 neutral’ are thrown around. These can be, and often are, challenged.

And as the Austrian ad regulator said with the Austrian Airlines case, most consumers have no idea what things like ‘SAF’ really mean.

The solution: Tell the story and don’t mark your own homework

Many airline executives have looked at what happened to KLM, Austrian Airlines and have been frightened off.

For example, SimpliFlying CEO Shashank Nigam has spoken to one airline boss who says that he’s not minded to publicise what the airline is doing as a result of the KLM example.

Environmental consultancy SouthPole has even come up with a name for it - “Green Hushing.”

SouthPole surveyed 1200 companies and found that a quarter that had set Science Based Targets don’t plan to publicise them.

We think that’s a mistake for a number of reasons:

1 - It surrenders the public arena. It means some of the very worthwhile sustainability initiatives are never talked about. Instead, all we hear about is how corporates (in this case airlines) are not serious about sustainability

2 - If we’re waiting for climate change groups to stop so we can tell our story, we’ll be waiting for a very long time. In any case, it’s their right in a democratic society to present their case.

3 - Good sustainability initiatives set an example and encourage others to come forward.

As Renée Morin, Chief Sustainability Officer at eBay says in the SouthPole press release , “Corporate climate action is a necessary and welcome ingredient to slowing the climate crisis. If more businesses lead from the front by speaking openly about their goals, this will spur the many others out there who are yet to set company targets – ideally ones

that are aligned with science.”

So how can airlines and airports credibly talk about sustainability initiatives?

We’d put forward two general principles:

1 - Tell the story: Rather than release campaigns with general phrases like ‘climate neutral flying’, tell the story of how you are pursuing sustainability. And not only that, make the passenger part of the story.

2 - Don’t mark your own homework: Have a credible third party organisation backup and ideally audit any claims you do make.

To take each of these in turn:

Tell the story

A lot of sustainable travel initiatives and technologies are inherently interesting. You can weave stories around them.

To take SAF as an example: In a previous section we mentioned both Swiss company Synhelion which turns sunlight into fuel, as well as Fulcrum, which takes household trash and uses it as the basis for SAF.

United is doing exactly that. As part of its “Good leads the way” advertising campaign, the airline produced ads saying, “this is the story of trash becoming fuel. It’s sci-fi without the fi.”

Then it says it is, “investing more in sustainable aviation fuel production than any other airline in the world.”

Note that the United ad doesn’t say anything about ‘carbon neutral flying.’ Instead it talks about trash into SAF, which is a thing. And then it highlights its investment in SAF..

It says in concrete terms what it’s doing to make flying less carbon intensive, and presenting it in an interesting way.

If anything, we think United can go further and actually involve the consumer in showing how his or her trash becomes jet fuel through videos, graphics and articles.

Activists might challenge the fact that household waste into fuel is a viable solution, in the past they’ve done so, but they can’t challenge the fact that it’s happening.

How much of a difference it makes in reducing emissions (and it does make a difference) can then be debated.

But the point is, it’s then a completely different debate to the one about whether ‘carbon neutral flying’ is true or false.

Similarly, earlier on we mentioned the report from Greenpeace Netherlands and DeSmog about airline advertising, which cited the fact that SAS talks about electric aeroplanes a lot.

That report was released in May 2022 and looked at ads that ran in 2021 immediately after the end of the COVID travel restrictions.

Since then, there has been a lot of progress when it comes to electric / hybrid-electric and hydrogen-electric aircraft, and again there is potential to tell a story.

In particular, if we take SAS as an example, it’s intending to buy the new Heart ES30 hybrid-electric aircraft, and is a Heart shareholder.

How can that agreement be brought to life? Here are a few examples.

First of all, new technology is interesting to the consumer and media if presented in the right way. Trevor Noah even did a segment on Air Canada’s commitment to buy 30 ES-30 aircraft on the Daily Show.

Sure, he had a lot of fun with it, joking for example if the pilot would have to ask passengers for their spare charging packs when the plane runs out of power, but the end result is a lot more people ended up knowing that Air Canada will be flying electric (or hybrid-electric) aircraft.

Electric aircraft also solve many of the problems associated with regional and subregional aviation - noise, operating cost and emissions.

The result is that many moribund commuter airports could be brought back to life.

NASA produced a report on this, looking at how more sustainable ‘Regional Air Mobility’ could result in you flying from the closest airport to you “that you never even knew you existed” (we discuss the NASA RAM study in our next generation aircraft report ).

As a result, use your investment in next generation aircraft to talk about how they can be transformational for a lot of communities, and how flying will become both more convenient and less carbon intensive. This can have a real impact, for you.

Also, talk about what the passenger experience will be like in flying in an aircraft with drastically lower noise levels - magniX and Harbour Air have some research here around their retrofitted Beaver aircraft, “showing noise energy levels that are at least 100 times lower.”

By doing all this, you make the customer part of your sustainability journey, while sticking to what you are actually doing and avoiding vague and easily challenged statements about being ‘CO2 neutral’ or similar.

Developing sustainability story-telling campaigns is one of the themes of our sustainability marketing master-class. See the end of the document for more details.

Don’t mark your own homework

Earlier we mentioned the Austrian Airlines Venice Biennale campaign, which was successfully challenged in front of the country’s advertising regulator. One problem is that it talked about ‘flying CO2 neutral, without anyone backing up the claims.

Having a credible third party on board is now crucial when it comes to verifying and assessing sustainability initiatives.

One of the best known, and one that airlines are starting to get on board with, is Science Based Targets.

Those targets are administered by the Science Based Targets initiative (SBTi). Companies submit their carbon reduction goals, and a team of experts then provides them with independent assessment and validation..

The partner organisations in SBTi are CDP (Carbon Disclosure Project), the UN Global Compact, WRI (World Resources Institute) and WWF (World Wildlife Fund). As a result, it’s credible and heavyweight.

Airlines that now adhere to science based targets include American Airlines, easyJet, Finnair, Air New Zealand and Air France-KLM. easyJet for example published a very ambitious net zero programme , relying a lot on the development of new hydrogen aircraft as well as carbon removals technology.

That roadmap has clear SBTi targets of a reduction in emissions of 35% by 2035.

There are other organisations as well who can assess and measure sustainability and net zero progress.

For example, during the recent APEX/ IFSA EXPO, amenity kit company FORMIA talked about how it was working with Dutch company REBEL .

According to FORMIA’s chief customer experience officer Marisa Pitsch, the collaboration with REBEL allows FORMIA to “turn all our concepts and dreams into data.” This is important as “otherwise it can be marketing hype and greenwashing. And we recognise how important that is to the airlines as well, that when they tell the story they can also back that up with data and information.”

Having a third party work with you is not foolproof, KLM works with SBTi, but is still being taken to court, but it does provide an important layer of validation and credibility. It makes greenwashing claims much harder to stick if you have someone backing up what you are doing.

source: easyJet

The greenconsumption effect and the benefits of getting it right

Finally, if you get your sustainability communications strategy right, there are real benefits in terms of building brand loyalty.

We explored this in more detail in our May report , but one element worth highlighting is the so-called Greenconsumption effectwhen people enjoy a product more when they know it is sustainable.

This thesis was tested and proven in an academic study, the results of which were published in the September 2019 issue of the Journal of Consumer Research .

The study found that:

“Using a green product influences the enjoyment of the accompanying consumption experience even if consumers have not deliberately chosen or purchased the product.

“Five experiments in actual consumption settings revealed that using a green (vs. conventional) product enhances the enjoyment of the accompanying consumption experience, referred to as the greenconsumption effect.“

One of the experiments involved giving participants a set of headphones and asking them to listen to 45 second excerpts from three songs.

One group was just given the headphones. The other group was given headphones and told that they were made from recycled materials.

The second group, who believed they were using ‘sustainable’ headphones, enjoyed the music more - despite listening to exactly the same songs and from the same headphones as the first group.

Headphones are of course a very relevant example for aviation, as they are a core part of an airline’s IFE system.

But really, the example works across the board. For example, easyJet automatically offset flights in 2019. In its Q4 2019 results, it disclosed that passengers who were aware of the offsetting were 11% more likely to recommend the airline.

Consumers are increasingly aware of the climate crisis and global warming. They want to do the right thing. If you do, and if you present what you are doing in an accessible way (based on facts), there are real benefits for your brand.

Avoiding the Greenwashing Trap

About SimpliFlying

Coming up to its 15th year in business, SimpliFlying is the world’s premier aviation strategic marketing firm.

Over the past fifteen years, we’ve worked with over 100 airports and airlines worldwide and since 2019 we’ve been actively engaged in the sustainability space, including with major aviation brands.

For example, recently we managed SAUDIA’s entry into the Skyteam Sustainable Flight Challenge , for which the airline won the award for best customer engagement.

This followed a sustainability lab on a Jeddah to Madrid flight where sustainability ideas were crowd-sourced from passengers and employees.

We regularly publish research about sustainability trends issues and technology, including next generation aircraft, carbon removals and air taxis.