Reputation warning for brands who fly close to the wind on environmental claims

March 3, 2023

“Connecting the world. Protecting its future.” Lufthansa’s ad slogan sounds good. It’s a nice, catchy, strapline. The trouble is, according to the UK’s Advertising Standards Authority and its rules around environmental claims in marketing communications, it’s only 50% true.

Read in isolation, the second clause in the slogan, the regulator said, “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.”

This gets into semantics, but tense here is important. The present tense ‘Protecting its future’ could be read, in the ASA’s view, by consumers to mean that Lufthansa’s business (‘Connecting the world’ via air travel) was positively contributing to the protection of the planet.

This is plainly not the case. Lufthansa is the first to admit it. That’s the whole point of its #MakeChangeFly campaign which sets out explicitly how the airline is investing in, and will achieve by 2050, CO2 neutral air travel.

The UK’s advertising regulators are taking an increasingly hard line on this kind of thing.

The ASA, jointly with the Committee of Advertising Practice (CAP), conducted a major piece of research with the results published last year, which analysed consumer’s understanding of terminology such as ‘net zero’. Among other things this identified the effect that carbon neutral and net zero claims could have on brand image (read, reputation). There was general cynicism about the motives of larger brands in making such claims. The research also noted that consumers acknowledged that companies in traditionally high carbon emitting sectors – including air travel – had a role to play in tackling the climate crisis but, again, brand tendency to declare environmental achievements was met with general cynicism.

CAP and the ASA have since released updated guidance for travel marketing, reflecting the rules as laid out in the Environmental Claims section of the CAP Code.

Here’s what caught Lufthansa out. Queue a series of less than favorable headlines, potentially undermining the positive reputation building work of the #MakeChangeFly campaign.

The Code sets a high bar when it comes to the substantiation required for green claims made, and that unqualified claims may mislead if they omit important information. Lufthansa’s ‘Protecting the world’ slogan / claim, read in isolation and independently of the specifics of its emissions reduction plans could potentially mislead.

These strictures clearly create a challenge for brands. Lufthansa is certainly not alone in being wrapped on the knuckles, with the likes of HSBC, Ryanair, Esso and Shell among those similarly sanctioned by the regulator in recent years on similar issues.

All companies have a role to play, however small, in the journey towards net zero and the transition to a cleaner economy. Solutions are emerging all the time, including in sustainable aviation fuels.

Consumers are increasingly making more ‘climate-informed’ purchasing decisions, while current and potential employees are making career choices to align themselves with companies which share their values.  Brands are therefore, understandably, seeking to project their sustainability credentials to remain competitive. Doing the right thing, but also being seen to be doing the right thing, is more generally to be welcomed as driving ever more awareness of climate issues and as generating further impetus for change as companies race to keep up.

But, clearly greenwashing is increasingly not tolerated by consumers, nor the media, other stakeholders, or regulators. As Lufthansa found out, even when there is an overall positive story to tell, the regulator will take a dim view if communications do not cross the Ts and dot the Is.

Environmental claims and communications must therefore be self-aware. Brands need to be honest with themselves. The net zero transition is an incredible economic opportunity, but slogans without substantiation pose a critical reputation risk.

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