Background
This Ruling forms part of a wider piece of enforcement work on climate change and the environment. The ad was identified for investigation following intelligence gathered by our Active Ad Monitoring system, which uses AI to proactively search for online ads that might break the rules.
Ad description
A paid-for Google ad for Lufthansa, seen in July 2023, stated “Fly now with Lufthansa […] Book your ticket directly with Lufthansa and explore destinations around the world […] Fly more sustainably”.
Issue
The ASA challenged whether the ad gave a misleading impression of the advertiser’s environmental impact.
Response
Deutsche Lufthansa AG t/a Lufthansa said that the ad had been created by the Google Callouts service from Google Ads, which highlighted options that customers could make use of in addition to a general flight booking. They said the callout “Fly more sustainably” was a reference to their “Green Fares” option, which passengers could select on European flights. They said that the “Green Fares” option would reduce 20% of flight-related CO2 emissions by using sustainable aviation fuels (SAF) and offsetting the remaining 80% of the CO2 emissions by an equivalent contribution to high-quality climate protection projects. Lufthansa said that 20/80 combination of reduction and offsetting was a new and unique option which they thought was worth informing potential customers about, to support SAF and high-quality climate protection projects. They believed that the claims seen in the ad were admissible comparative claims, in line with the CAP Code, because the fare option offering a combination of CO2 reduction and offsetting differed from the general fare options offered by them and their competitors.
Lufthansa said that the technical limits of Google Callouts meant that only very limited information could be provided in such an ad. They believed that an average consumer and Google user was aware of that limitation, and did not expect fully-fledged substantiation to appear in a Callout in a search result, but would instead follow the link provided by the search result to get further information.
Lufthansa said that they had instructed their agency to remove the sentence “Fly more sustainably” from their Google Callouts going forward.
Assessment
Upheld
The CAP Code stated that the basis of environmental claims must be clear. Unqualified claims could mislead if they omitted significant information. Comparative claims could be justified if the basis of the comparison was clear.
The ASA considered that consumers would understand the claim that people could “Fly more sustainably” with Lufthansa to mean that they offered a way to travel by air that had a lower environmental impact than alternative airlines. The ad did not clarify how the claim “Fly more sustainably” worked in practice, and the basis of the claim was likely to be material information which consumers would need in order to make an informed decision.
While we noted that flying with the Green Fares option used “sustainable aviation fuel” as part of the fuel mix for that flight and made contributions to climate protection projects, and that this might decrease some of the negative environmental impact of flying with Lufthansa, we considered that the basis for the claim "Fly more sustainably” had not been made clear in the ad. Although we accepted that space in a search result ad was limited, we did not consider that meant that material information of such relevance could be omitted.
While we welcomed Lufthansa’s decision to remove the sentence “Fly more sustainably” from future ads, we therefore concluded that the ad gave a misleading impression of Lufthansa’s environmental impact, and that the ad breached the Code.
The ad breached CAP Code (Edition 12) rules 3.1 (Misleading advertising), and 11.1 and 11.3 (Environmental claims).
Action
The ad must not appear again in the form complained about. We told Deutsche Lufthansa AG t/a Lufthansa to ensure that their ads did not give a misleading impression of the impact caused by travelling with the airline, and that robust substantiation was held to support all objective claims.
