Lufthansa ad campaign to protect the environment fails to fly with the ASA
Can an airline claim to be protecting the environment?
The question
Can an airline claim to be protecting the environment?
The key takeaway
The ASA has ruled that an ad for the German airline Lufthansa gave a misleading impression of the extent of the airline’s environmental impact. The decision underlines just how hard it is for businesses in non-environmentally friendly industries to make green claims, and how broad, absolute environmental claims are almost always impossible to substantiate.
The background
A poster ad for the German airline Lufthansa included an image of the top half of a plane which was in flight, with half of a globe at the bottom half and carried the line “Connecting the World. Protecting its Future. #MakeChangeFly”. The ASA sought to investigate whether the ad gave a misleading impression of Lufthansa’s environmental impact.
In its response to the ASA’s investigation, Lufthansa said the purpose of the ad and wider #MakeChangeFly campaign was to address the need to reduce the impact of air travel on the environment and to raise awareness amongst consumers of how Lufthansa is achieving this. It said that the website, which consumers were directed to through the ad via a hyperlink to www.makechangefly.com, was the primary source for this awareness, rather than the ad itself.
Lufthansa also argued that the slogan “Connecting the World. Protecting its Future” was open to interpretation but would not be understood by consumers as an absolute promise that their service caused no harm to the environment. It emphasised that “Connecting the World” was not an absolute claim and insisted that it could therefore be extrapolated that the second half, “Protecting its Future”, was not an absolute claim either. It explained that the slogan would be seen as a mission statement intended to draw people to the website, which provided more context for the ad, in order to raise awareness of the environmental impact caused by air travel and the steps Lufthansa was taking to address them.
The development
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, it 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.
The ASA understood that the campaign was based on steps Lufthansa was taking as part of its aspirations to become more environmentally friendly at targeted points in the future. However, viewing the ad without the context of the accompanying website was likely to be interpreted by consumers as meaning that Lufthansa had already taken significant steps to mitigate the net harmful environmental impacts of its operations on the environment. The fact that the ad directed consumers to the website was therefore not sufficient to substantiate its claims given the fact that the ad could and would still be viewed in isolation by consumers.
The ASA also pointed out that air travel produces high levels of climate changing CO2 as well as non-CO2 emissions and that there are currently no environmental initiatives or commercially viable technologies in the aviation industry which could substantiate the absolute green claim that Lufthansa is protecting the future of the planet
Why is this important?
This is yet another example of a brand who has fallen foul of the ASA’s rules on environmental claims, after the watchdog made promises in 2021 to crackdown on greenwashing. In 2022 the number of ads banned for environmental claims that could not be substantiated tripled from the previous year; those involved included HSBC, Innocent Drinks Oatly, Pepsi’s Lipton and Unilever’s Persil detergent. Miles Lockwood, the director of complaints and investigations at the ASA, gave the reminder that advertisers should not make environmental claims that mislead consumers about their green credentials which they cannot substantiate with robust evidence.
Any practical tips?
It is imperative that companies understand the ASA’s CAP Guidance in its entirety. Of particular importance in this arena is the Advertising Guidance titled “The environment: misleading claims and social responsibility in advertising”.
Failure to comply with the rules surrounding substantiated claims can give rise to immense wasted costs on advertising campaigns that ultimately get banned. There is also a significant risk of reputational damage when both a company’s actual environmental impact and its overall integrity and authenticity are brought into question.
Summer 2023