A poster for Lufthansa, seen in June 2022, featured an image of the front of a plane in flight. The underside of the plane was represented by an image of the earth from space. The ad included text which stated, “LUFTHANSA GROUP. CONNECTING THE WORLD. PROTECTING ITS FUTURE. #MakeChangeFly”.
The ASA challenged whether the ad gave a misleading impression of the advertiser’s environmental impact.
Deutsche Lufthansa AG t/a Lufthansa said that the ad contained a clear hyperlink to the website www.makechangefly.com, which formed part of the wider “#MakeChangeFly” campaign. The purpose of the ad and wider campaign was to address the need to reduce the impact of flying on the environment and making consumers aware, chiefly via the website, of how Lufthansa were achieving that.
They said that the tagline, “CONNECTING THE WORLD. PROTECTING ITS FUTURE” was open to interpretation, but in conjunction with the imagery it would not be understood as an absolute promise about their service, especially one linked to the environment, that their services caused no harm to the environment. They said it was also important to emphasise that “CONNECTING THE WORLD” was not an absolute claim and that it would therefore be inconsistent to conclude the second half of the tagline, “PROTECTING ITS FUTURE” was absolute, when the former part was not.
They explained that the imagery of half a plane and half a globe even presented the tagline as a potential dichotomy. In addition, the tagline in the ad contained no absolute statement stating that flying, or Lufthansa, had no impact on the environment and it would be incorrect to conclude the average consumer would understand the slogan in that way. They said that “PROTECTING ITS FUTURE” would not be understood by consumers as a narrow and distinct reference to protecting the environment and the slogan would be seen by consumers as a mission statement intended to draw people to the website to raise awareness of the environmental issues related to flying and the steps Lufthansa had taken to address them. It was only by going to the website was the ad clearly linked to environmental claims and the website had sufficient explanation and was clearly qualified.
The website stated that air transport connected people, countries and cultures and that its economic importance was wide ranging, creating employment and transporting goods. The website also made clear that Lufthansa were aware that the aviation industry emitted CO2, which had a negative impact on the environment. It was for that reason the website stated that they took their responsibility to climate change seriously and outlined the steps they were taking to protect the environment such as highlighting the purchase of new aircraft with lower fuel consumption and how Lufthansa were one of the largest purchasers of Sustainable Aviation Fuel. They said any consumer who saw the ad would be able to see, via the website, the environmental impact of air travel and Lufthansa’s actions to mitigate it. The website therefore provided context and substantiation for the ad. Due to the qualifying information in the ad, via the website link, consumers would not be misled as to Lufthansa’s environmental impact.
The CAP Code required that absolute environmental claims must be supported by a high level of substantiation.
The ASA acknowledged Lufthansa’s view that the claim, “CONNECTING THE WORLD. PROTECTING ITS FUTURE” in isolation was ambiguous and not clearly linked to the environment. However, we considered that the claim “PROTECTING ITS FUTURE” was likely to be interpreted by consumers as an environmental reference to how Lufthansa's approach to aviation was protecting the future of the world, given that this text appeared immediately after the text “CONNECTING THE WORLD” and was superimposed on a picture of the globe.
We noted Lufthansa’s comments that the campaign was based on specific steps taken to be more environmentally friendly, including aspirations to become carbon neutral by 2050 and to cut carbon emissions in half by 2030. However, the claim “PROTECTING ITS FUTURE” was not qualified with this information. We considered the claim was likely to be understood by consumers to mean that Lufthansa had already taken significant mitigating steps to ensure that the net environmental impact of their business was not harmful.
We understood that air travel produced high levels of both CO2 and non-CO2 emissions, which were making a substantial contribution to climate change. We noted the initiatives and targets Lufthansa said they were committed to delivering in pursuit of their stated goal, but many of these initiatives were targeted to deliver results only years or decades into the future. We also understood that there were currently no environmental initiatives or commercially viable technologies in the aviation industry which would substantiate the absolute green claim “PROTECTING ITS FUTURE”, as we considered consumers would interpret it.
We concluded that, because the basis of the claim had not been made clear and it had not been adequately substantiated, the ad breached the Code.
The ad breached CAP Code (Edition 12) rules 3.1 (Misleading advertising), and 11.1, 11.3 and 11.4 (Environmental claims).
We told Deutsche Lufthansa AG t/a Lufthansa to ensure that the basis of future environmental claims was made clear and did not give a misleading impression of the impact caused by travelling with the airline and that robust substantiation was held to support them