Background

This Ruling forms part of a wider piece of work on airline industry advertising and environmental claims. 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 airline Wizz Air, seen on 9 June 2024, stated “Fly Wizz Air – one of the greenest choices in air travel”.

Issue

The ASA challenged whether the claim “one of the greenest choices in air travel” was misleading.

Response

Wizz Air Hungary Ltd (Wizz Air) said it had committed billions of Euros to aiding the airline industry’s decarbonisation efforts. They operated the youngest and most carbon-efficient fleet in Europe, with an average age of 4.3 years. As a result, they had the lowest carbon emissions per passenger at 52 g carbon dioxide per revenue passenger kilometres (CO2/RPK). RPK was the number of seat kilometres flown by paying passengers – a figure that had been independently verified. They provided a copy of the report from which the figure had been taken.

Wizz Air explained that they were actively renewing their fleet of aeroplanes – replacing the Airbus A320ceo aircraft with the Airbus A321neo, with a reduction in fuel consumption of 10% and a per-seat fuel improvement of 20%. The Airbus A321neo was the widest and most efficient single-aisle aircraft with the lowest fuel consumption per seat kilometre in its category. Additionally, the newer model gave a 50% reduction in noise compared to the older model.

Wizz Air had invested in the research and development of sustainable aviation fuel (SAF). They were an equity investor in SAF, having invested in two companies developing the fuel, and had concluding offtake agreements to purchase SAF once it had been produced. They aimed to reach 10% SAF usage by 2030, exceeding the ReFuel EU Aviation Regulation requirements. They held membership of the Alliance for Zero Emission Aviation (AZEA) and the Renewable and Low-Carbon Fuels Value Chain Industrial Alliance (RLCF) to ensure investment and deployment of future technologies in the field.

As part of its environment, social and governance strategy (ESG) Wizz Air had established an independent Sustainability and Culture Committee and appointed a dedicated ESG Officer, who was a member of the senior leadership team. The independent Committee ensured the company took environmental issues into account when defining the Company’s strategy. As part of its duties, the Committee ensured Wizz Air’s statements on sustainability adhered to legislation, and that claims were verified by data, assurance and benchmarking.

Assessment

Upheld

The CAP Code stated that the basis of comparative claims such as "greener" or "friendlier" must be made clear. It also required that comparisons with identifiable competitors were verifiable and needed to include, or direct consumers to, sufficient information to allow them to understand the comparison, and be able to check the claims were accurate, or ask someone suitably qualified to do so.

The ASA considered consumers would understand the claim “one of the greenest choices in air travel” in the ad as meaning that Wizz Air’s environmental impact was among the lowest of all the airlines operating flights to and from the UK.

While we acknowledged that Wizz Air had based the claim on the type of aircraft they used, and the carbon emissions per passenger measured in CO2/RPK, that was not stated in the ad. Furthermore, the ad had not included information that would allow consumers to understand the comparison.

Because the ad had not made clear the basis of the claim, or provided verifying information, we concluded it had breached the Code.

The ad breached CAP Code (Edition 12) rules 3.1 (Misleading advertising), 3.33, 3.35 (Comparisons with identifiable competitors), 11.1, and 11.3 (Environmental claims).

Action

The ad must not appear again in the form investigated. We told Wizz Air Hungary Ltd to ensure the basis of future comparative environmental claims was made clear and did not give a misleading impression of their flights’ environmental impact, and that ads provided sufficient information to enable consumers to verify comparisons with identifiable competitors or signposted consumers to such information.

CAP Code (Edition 12)

3.1     3.33     3.35     11.1     11.3    


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