The aviation industry currently finds itself in a tricky position – a high greenhouse gas emitting sector with ever increasing demand operating in the midst of climate change and the confines of net zero targets. Enter Sustainable Aviation Fuel (SAF), which is aiming to play a key role in helping to tackle climate change by significantly reducing flight carbon emissions.
While the ASA hasn’t seen too many examples of SAF claims in ads, plans have already been put in motion to increase its use in the sector and so there will, quite understandably, be increased opportunities for advertisers to highlight how it’s being implemented. There are positive messages to be communicated with this concept, however there’s always a balance to be struck in ensuring that those messages don’t give a misleading impression of the environmental impacts of flights through its use.
Here we’ll outline some key green claim requirements so you can get that balance right.
What is Sustainable Aviation Fuel?
SAF is an alternative aviation fuel made from renewable feedstocks, which can range from general household waste and cooking oil, to waste wood and algae (and lots in between). SAF purports to offer a lower carbon alternative to traditional fossil-based jet fuel, with the aim of significantly reducing carbon emissions. The term itself is widely used and recognised in the aviation sector, as well as government, and was first defined by organisations like the International Civil Aviation Organisation (ICAO) and the International Air Transport Association (IATA).
Unlike other alternatives to traditional aviation fuel, SAF’s chemical make-up means that it can be easily integrated – or ‘blended’ – into current fuel mixes, at a current maximum ratio of 50%. It can also be used in existing aircraft, resulting in minimal impact on infrastructure.
To encourage and secure demand, the UK government implemented a SAF Mandate in 2024, which sets a legal obligation on its supply. This starts in 2025 at 2% of total UK jet fuel demand and then increases annually to 10% in 2030 and finally 22% in 2040. It’s estimated that the Mandate could deliver up to 6.3 megatonnes of carbon savings per year by the final increase in 2040.
Make sure you make the basis of the claim clear
When it comes to the content of ads, they need to make the basis of any environmental claims clear. This means that any unqualified claims could mislead if they omit significant information. Additionally, the meaning of all terms used in ads should be clear to consumers.
Results from various ASA consumer research topics (be it related to food, EV and hybrid vehicles, green disposal methods or carbon neutral claims) have shown that there’s typically quite a low level of understanding, and often confusion, when it comes to grasping the meaning of environmental claims. This includes references to new technologies, a bracket that SAF is likely to fall into.
On the basis that consumers will lack in-depth knowledge and understanding of SAF, any negative environmental impacts of the fuel could be considered as material information that will have an impact on a transactional decision. Ads that don’t highlight this type of balancing information are therefore likely to mislead. What we’re considering here is something that explains that SAF produces reduced, but still significant, emissions over its full life cycle (more on that later), and the level of greenhouse gas emission savings that have been obtained.
The consumer’s perspective is therefore key – first, what is the ad’s overall message? What is that likely to mean to them? What’s their likely understanding and interpretation of it? What information are they going to need to help their understanding?
What about absolute claims?
A good place to start when making any objective claim is to make sure that you hold evidence to substantiate it. Absolute claims (like “green” or “eco-friendly”) have historically been taken to mean that something either has no effect on the environment or an actively positive one and will therefore require a very high level of evidence to back them up.
The term “Sustainable Aviation Fuel” is unlikely to be taken as an absolute claim in isolation, but you’ll want to avoid accompanying it with absolute-style descriptors. As we’ve already seen, while the transition to SAF aims to spark a positive shift on climate change compared to using jet fuel, there will still be some unavoidable impact on the environment through its use. This isn’t exclusive to SAF – it’s simply a nigh on impossible task to back up a suggestion that a product or service has absolutely no effect on the environment in some way, however small that might be.
So, if you want to claim “Environmental Advocacy” with “Total Peace Of Mind”, “a louder, bolder approach to sustainable aviation” or that consumers can “travel better and sustainably”, you’ll probably have a difficult time justifying it.
What could work instead is a claim comparing against a previous product or competitor product (“greener” or “friendlier”). In a SAF context, where different types of SAF exist and uptake may differ between airlines, this might be “one of the greenest” or “Fly more sustainably”, although remember that you’ll need to include the basis for which the claim has been used and be able to substantiate it.
Take into account the full life cycle
Generally the more specific and narrow the claim, the easier and more straightforward it will be to substantiate it. This is particularly relevant considering that, unless an ad states otherwise, environmental claims will need to take the full life cycle of the product or service into account – this means assessing its impact in its entirety, from cradle to grave (or from maiden flight to fini-flight if you’ll indulge me another aviation reference).
For SAF this might include the more obvious environmental impact of the flight itself, but also any impact that results from its production. This will differ depending on the type of SAF, but the ASA has previously seen examples including the diversion of biofuels from other sectors which might then revert back to fossil derived fuels, and the impact of land use changes, both direct and indirect. Where services are directly linked with aviation, it’s likely that claims will be taken in the context of the full life cycle of aviation operations generally, including where aircraft aren’t directly owned or operated.
Remember that nigh on impossible task mentioned earlier for absolute claims?
You might instead attach an environmental claim to a specific part of the process (the flight only for example), and that means that you would only need to hold evidence for the life cycle of that specific part, rather than the whole.
What can often be effective is taking a step back from the creative process at the initial stages and approaching it from a different angle. What claim would you like to make? What evidence do you currently hold? Is there enough there to make a more limited or specific claim? What evidence would you need to help substantiate a broader claim and is that achievable?
SAF being unique to your business and exaggerating fuel mix
You might argue that as a concept SAF is unique, but the practical use of it won’t be. The SAF Mandate is a legal obligation for fuel suppliers in the UK, so it’s important to remember that other companies will be adhering to it as well. If you refer to SAF in your ads, be careful that you don’t suggest that it’s an exclusive initiative or something that only you’re implementing. Be careful to also ensure that you don’t exaggerate your company’s role in the use and uptake of SAF.
Similarly, you’ll want to avoid any suggestion that your fuel mix contains more SAF than it actually does. There’ll be quite a few ways of achieving this, but initially you’ll want to have the likely interpretation in mind. For example, you might think about avoiding blanket statements, making clear in some way that the fuel mix contains SAF in part, or including the specific percentage of SAF contained within the fuel mix.
Further help & reading
CAP offers a wide range of support for advertisers to help navigate any uncertainty with environmental claims. For bespoke advice on any non-broadcast ads, the Copy Advice team is always here to help, and a copy of our formal Environmental Guidance can be found here.
The ASA and CAP would like to extend its thanks to the various trade bodies and government officials who provided invaluable information and insight into SAF use in the UK for the purposes of this article.
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