Background
Summary of Council decision:
Two issues were investigated, both of which were Upheld.
Ad description
Two paid for Facebook ads seen in October 2022:
a. Text stated, “We understand the impact flying has on the environment. That’s why we are taking a louder, bolder approach to sustainable aviation”. An accompanying video showed an Etihad plane flying. Then on-screen text stated, “With Etihad you’ll earn Etihad Guest Miles …” above an image of a card with a plant coming out of it. The card had the text, “ETIHAD GUEST CONSCIOUS CHOICES”. An image of the world appeared, above on-screen text that said, “… every time you make a Conscious Choice for the planet”. An image of the world was shown quickly passing by. On-screen text said, “Environmental Airline of the Year for 2022 in the Airline Excellence Awards”. This was beneath an image of a golden rosette with the text in the middle which said, “Airline Ratings ENVIRONMENTAL AIRLINE OF THE YEAR ETIHAD AIRWAYS 2022”.
b. This ad included the same text as ad (a). An accompanying video showed an Etihad plane in flight. On-screen text said, “At Etihad, we are cutting back …”. Then an image of a tray and cutlery was shown. On-screen text in the middle of the tray said, “… on single-use plastics … and are flying the most modern and efficient planes. Flights with a smaller footprint”. An image of a golden rosette was shown with text in the middle which said, “Airline Ratings ENVIRONMENTAL AIRLINE OF THE YEAR ETIHAD AIRWAYS 2022”. On-screen text beneath that said, “Environmental Airline of the Year for 2022 in the Airline Excellence Awards ETIHAD AIRWAYS Discover more at etihad.com/sustainability”.
Issue
The ASA challenged whether ads (a) and (b), and particularly the following claims, were misleading, because they exaggerated the environmental benefits of flying with Etihad:
1. ad (a), “… we’re taking a louder, bolder approach to sustainable aviation” in the body of the text and “… you’ll earn Etihad Guest Miles every time you make a conscious choice for the planet … Environmental airline of the year” in the accompanying video; and
2. ad (b), “… we’re taking a louder, bolder approach to sustainable aviation” in the body of the text and “… we’re cutting back on single-use plastics and are flying the most efficient planes. Flights with a smaller footprint … Environmental airline of the year” in the accompanying video.
Response
1. & 2. Etihad Airways stated that the claim “sustainable aviation” in ads (a) and (b) was not intended to be understood as an absolute solution to the environmental impact from aviation and they did not accept that they would be interpreted in that way. In contrast they said the claim would be widely understood as a long-term and multi-faceted process, in which Etihad had included an aspiration to reach “net zero” carbon emissions by 2050.
They said “sustainable aviation” had been a widely used and publicised term in the aviation industry for a number of years and was used by the European Union Aviation Safety Agency (EASA). Further to that Etihad’s sustainability strategy was in line with EASA’s sustainability priorities and incorporated initiatives by Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA), International Civil Aviation Organization (ICAO) and the United Arab Emirates (UAE) government. It focused on solutions to fast-track the transition to cleaner fuels, develop a carbon credits ecosystem locally and support strong standards globally, explore and develop emissions avoidance mechanisms through non-CO2 effects and engaging Etihad’s customers and stakeholders in supporting de-carbonisation.
That multi-faceted approach meant Etihad had to take “bolder” decisions than before, putting in place new initiatives and technology within a coherent strategy focused on sustainability. They provided examples of that “bolder” approach which included a restructure of their fleet to use modern, fuel efficient aircraft. The development of Sustainable Aviation Fuel production in the UAE, in a project that looked at energy and food security. The testing of contrail management mechanisms and optimisation of aircraft descent and ascent operations to save fuel. The use of the latest digital navigation charts and Auxiliary Power Unit (APU) burn management methods to find the most efficient way to fly. They had further received support from the Botanical Garden’s Conservation Initiative’s Global Diversity standard, the only international certification that recognised and promoted the protection and restoration of biodiversity. They had engaged Etihad guests and stakeholders in their Conscious Choices programme, which for guests aimed to encourage and reward environmentally friendly habits and for stakeholders aimed to help Etihad to integrate Sustainable Aviation Fuel in their operations. Finally they had also approached local and global regulators to promote ICAO’s goal to reach net zero by 2050 and supported the UAE government in the sector’s net-zero resolution.
Etihad said they had also achieved a number of awards which evidenced their “louder, bolder approach to sustainable aviation”. Those included a stage two certification from International Air Transport Association (IATA) Environment Assessment Programme, a bronze EcoVadis rating, the “Best Airline For Sustainability” from American Business Traveller, a 2022 sustainability award by Nat Geo Traveller China, an “Environmental Sustainability Innovation of the Year” award from CAPA and environmental airline of the year 2022 in the Airline Ratings awards.
Assessment
1. & 2. Upheld
The CAP Code required that absolute environmental claims must be supported by a high level of substantiation.
Ads (a) and (b) stated that because Etihad understood the impact flying had on the environment, they were “taking a louder, bolder approach to sustainable aviation”. While the accompanying video in ad (a) mentioned, “Etihad Guest Miles”, “ETIHAD GUEST CONSCIOUS CHOICES” and said that they had won an environmental award, it gave no further context or explanation as to how “sustainable aviation” was being achieved. The video in ad (b) said Etihad were cutting back on single-use plastics, flying with the most modern and efficient planes which had a “smaller footprint” and had won an environmental award. However, we considered such qualifying information was material to consumers' understanding of the claim, and without it being made clear in the initial text, consumers would understand the "sustainable aviation" claim to be about Etihad's whole business.
The ASA acknowledged Etihad’s comments that the claim “sustainable aviation” would be understood, especially in the aviation industry, as a long-term, multifaceted goal, which included their aspiration to reach “net zero” carbon emissions by 2050. However, we noted that the ads were aimed at the general public and not specifically at those in the airline industry and that neither ad mentioned Etihad’s desire to be “net-zero” by 2050 or positioned the claim “sustainable aviation” as a long-term aspiration.
We acknowledged Etihad’s comments about the use of modern aircraft and flight practices to reduce emissions. We understood, however, that air travel continued to produce high levels of CO2 and non-CO2 emissions which were making a substantial contribution to climate change. We noted the further initiatives and targets Etihad said they were committed to delivering in pursuit of their stated goal but many of these initiatives were targeted to only deliver results years or decades into the future. Further to that, initiatives such as reducing single use plastics and using more efficient aircraft were not adequate substantiation to evidence a "sustainable aviation" claim.
While we noted steps were being taken by Etihad to reduce the environmental impact of its service, we understood that there were currently no initiatives or commercially viable technologies in operation within the aviation industry which would adequately substantiate an absolute green claim such as “sustainable aviation” as we considered consumers would interpret it in this context.
We concluded, therefore, that the claim exaggerated the impact that flying with Etihad would have on the environment and the ads breached the Code.
The ads breached CAP Code (Edition 12) rules 3.1 (Misleading advertising), and 11.1, 11.3 and 11.4 (Environmental claims).
Action
We told Etihad Airways 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 them.
