Travel

A post on the advertisers’ LinkedIn page stated:

“Investing in Sustainable Aviation Fuel (SAF) is one of the ways we are working to reduce our environmental impact. Made from renewable sources, SAF typically has approximately 80% lower carbon emissions compared to traditional jet fuel over its lifecycle. Earlier this year, we received the first delivery of SAF at Dublin Airport – an important milestone.

Watch below for a behind the scenes look at how we’re working with our partners to introduce SAF to our Dublin operations.”

The video voiceover stated:

“Aer Lingus is proud to take a major step forward on our sustainability journey, importing sustainable aviation fuel, or SAF, into Dublin for the very first time. This is a key milestone for Aer Lingus and for Irish aviation. In 2025, new EU regulations will require 2% of all aviation fuel supplied at European airports to be SAF. This year we’re scaling up our SAF usage, targeting the import of approximately 7,000 tonnes of SAF into Dublin. Unlike traditional fossil jet fuel, SAF is produced from renewable waste materials, like cooking oil. When used in flight, SAF produces similar levels of carbon dioxide to conventional fuel, but is already part of the carbon cycle, and it’s not extracted from the ground specifically for creating aviation fuel. That means using SAF typically results in a reduction in emissions of 80% compared to the jet fuel it replaces over its lifecycle. This makes SAF the most effective and immediate way aviation can reduce its environmental impact. The SAF we’re using meets rigorous international certification standards and is safely blended with conventional jet fuel before being transported through existing infrastructure from storage at Top Oil’s terminal in Dublin Port to the Dublin Airport fuel farm. The fuel farm itself plays a vital role, where the majority of fuel is delivered using a hydrant system connected to parked aircraft, cutting down the need for truck deliveries and improving efficiencies on the ground. This first import into Dublin was made possible through close collaboration across teams in Aer Lingus, IAG, and our external partners. Sustainability remains a key pillar of our strategy and bringing SAF to Dublin is an important milestone we’re proud of. Together we’re working towards a better, more sustainable future, one flight at a time.”

The complainant objected to the advertisement on the following grounds:

Issue 1:
The complainant considered the statement “This means that SAF is the most effective and immediate way aviation can reduce its environmental impact” was an absolute claim that was misleading. As grounds for their complaint, the complainant referred to a press release from the Environmental Protection Agency which stated that greenhouse gas emissions from aviation increased by just under 17% compared to 2023, reflecting growth in the sector. The complainant also referred to a publication by Opportunity Green , which said that growth in air travel was outpacing any impacts of purported technological advancements, including the introduction of SAF and that it was projected to continue. The complainant also referred to a Joint Research Centre document as part of their complaint.

Issue 2:
The complainant objected to the advertising on the grounds that no qualification had been given about ‘SAF’, such as its limitations and environmental concerns, including that it was not immediately available in the quantities required to reduce aviation’s environmental harm and nor would it be for several years. (The Conversation.com )

Issue 3:
The complainant referred to a complaint in 2023 by the European Consumer Organisation (BEUC) against climate-related claims by several European airlines, which had led to the EU Commission and the Network of Consumer Protection Cooperation (CPC) Authorities saying that they ‘had identified several types of potentially misleading practices by those airlines when using the term “sustainable aviation fuel”, without clearly justifying the fuels’ environmental impact”. The complainant said that an analysis of the finding was that ‘SAF’ was a vague, umbrella term that was used indiscriminately by the industry, but which in reality included a range of fuels, from biofuels to green hydrogen-derived e-fuels, which varied in how environmentally friendly they were.

The advertisers responded to the issues raised.

Issue 1:

The advertisers said that when the statement “This means SAF is the most effective and immediate way aviation can reduce its environmental impact” was taken as a whole and in context, the video conveyed plainly that SAF was the principal near-term pathway available to aviation to reduce its lifecycle greenhouse gas emissions when compared with conventional jet fuel. They said that this was because SAF could be deployed in existing aircraft and fuel systems right away while longer-term technologies matured. They said that this position was well established and substantiated by authoritative industry and by regulatory and government sources.

Furthermore, they said that the use of the phrase “most effective and immediate” was not misleading. They said that the video provided an update on Aer Lingus’s importation and use of SAF into Dublin and was intended to explain, in plain language, why SAF was treated, including by policymakers and industry experts, as a near-term tool for airlines in their efforts to decarbonise, that could be used in existing operations. For this reason, they said it was appropriate, correct and in no way misleading:

(i) to say “immediate” in the context that SAF was available today as what is known as a ‘drop-in’ fuel and was compatible with existing aircraft types and fuel storage and delivery infrastructure, as such it could be used by airlines immediately. They said that the Irish Department of Transport noted in its Sustainable Aviation Fuel Policy Roadmap (August 2025 ) that the use of and development of sustainable aviation fuels would be pivotal “in the short to medium term” given the absence of immediate alternative means of propulsion at commercial scale. They said that the Policy Roadmap stated that “SAF offers an immediate and safe solution that can work with existing aircraft and infrastructure, whilst new technologies develop”. Accordingly, that “immediacy” (based on the fact that SAF was already aircraft and airport refuelling system compatible and available to deploy today) was acknowledged in national policy materials.

or

(ii) to say “most effective” in the context that current technical and policy analyses identified drop-in fuels as the foremost technology currently available for aviation to address decarbonisation. Specifically:
ICAO in its 2022 Report on the Feasibility of a Long-Term Aspirational Goal for International Civil Aviation Co2 Emission Reductions (‘LTAG Report’) recorded that “Drop-in fuels have the largest impact on residual CO₂ emissions driving the overall reductions by 2050”; and the European Commission in its 2025 Sustainable Transport Investment Plan Communication similarly framed renewable and low-carbon fuels as “particularly critical” for aviation because aviation could only marginally benefit from electrification. The European Commission recorded in that Communication that ICAO recognised SAF “…as the main enabler to emission reductions…” and that investing in renewable and low-carbon fuel technologies was crucial for decarbonisation.

They said that read together, these technical and regulatory sources substantiated the meaning of the “most effective and immediate” wording in context: namely that, as a matter of decarbonisation strategy in aviation, SAF as a drop-in fuel was identified in ICAO and EU policy and analysis (and reflected in Irish governmental policy) as the leading near-term measure to reduce aviation’s lifecycle CO₂ emissions, particularly relative to other pathways which were not available at scale in the short to medium term.

They said that the complaint had treated the phrase “most effective and immediate” as an absolute environmental claim, however, the video had not stated, either expressly or impliedly, that SAF eliminated emissions or that aviation became environmentally ‘harmless’ by using SAF. They said that, on the contrary, the presenter in the video expressly stated that SAF produced similar levels of CO₂ to conventional fuel when burned, but that emissions reductions arose because the production of SAF had a different carbon lifecycle profile to fossil fuel and it was that differing production lifecycle which gave rise to reduced emissions when compared to fossil fuels.

The advertisers stated that the claim in the complaint that growth in air travel was outpacing the impact of technological advancements such as the introduction of SAF was a complaint about sector-wide emissions volumes and growth, rather than any statement made in that regard in the advertisement.

They said that the video was not a representation that overall sector emissions would necessarily fall irrespective of demand for air travel; rather it explained why SAF was an important measure available to the aviation industry in pursuing emission reductions, which was consistent with the framing of the issue by the regulators and policy makers referred to above. They said that they did not dispute that broader issues existed in relation to aviation emissions trajectories and indeed ICAO in its LTAG report did recognise that overall traffic growth rate impacted residual emissions; but those issues did not render a statement that SAF was a leading near-term tool to reduce emissions intensity on a lifecycle basis (when compared to conventional fuel) in any way misleading.

Issue 2:

The advertisers acknowledged that there were market challenges, such as cost differentials and production investment barriers, around the availability of renewable and low-carbon fuels. However, they said that the regulatory framework in the European Union was designed to scale SAF supply and demand over time. In that context, they said it was not misleading to describe SAF as “immediate” (i.e., deployable today as a drop-in fuel) and “effective” (i.e., a leading decarbonisation tool recognised as such by ICAO and EU policy), while accepting that scaling was a challenge being addressed through policy and investment measures.

As to environmental aspects and limitations, they said that the video explained that SAF production involved the use of renewable feedstocks rather than fossil extraction, described the emissions reductions benefits in SAF lifecycle terms, had made the explicit qualification that SAF had the impact of producing similar levels of CO₂ to conventional fuel when burned; and was transparent about the requirement that SAF was blended with conventional fuel and was subject to safety and environmental certifications. They said that the video also stated that the SAF used by Aer Lingus was subject to international certification standards.

Issue 3:
In response to the reference in the complaint to the EU Network of Consumer Protection Cooperation Authorities coordinated action targeting misleading climate-related claims, including SAF claims, by some European airlines, they said that Aer Lingus was not an airline subject to that action. To the extent that it addressed the use by airlines of the term ‘sustainable aviation fuel’ without referring to its environmental impact, they pointed out that the video clearly mentioned the emissions impact of SAF as well as the environmental aspects and limitations referred to above.

The Complaints Council considered the detail of the complaint and the advertisers’ response.

Issue 1 Not Upheld:

The Council noted that the advertisement had stated that investing in SAF was “one of the ways we are working to reduce our environmental impact” and had also included a description of what SAF is, and that it could be used in existing aircraft fuel systems immediately while longer term technologies matured. While the Council noted the concerns raised in the complaint, they also noted that the development of, and use of, sustainable aviation fuel was recognised by the Department of Transport, the ICAO and the European Commission in the medium to short term given the absence of longer term solutions. In the circumstances, the Council considered that in the context of what is available to the airline sector currently, they did not consider that the advertising claim was in breach of the Code on the grounds raised at Issue 1.

Issue 2 Not Upheld:

The Council noted that the advertisement had included the statement that investing in SAF was “one of the ways we are working to reduce our environmental impact” at the beginning of the post and made reference to the EU regulatory requirement that 2% of all aviation fuel supplied at European airports was to be SAF. They also noted that the advertisement stated “This year we’re scaling up our SAF usage, …”The Council noted that while there were market challenges, the regulatory framework in the EU was designed to scale SAF supply and demand over time. The Council also noted that the advertisement had included information as to where SAF was sourced, and that it was mixed with conventional fuel. In the circumstances, the Council did not consider that the advertisement over-stated the availability of SAF and therefore was not in breach of the Code on the grounds raised at Issue 2.

Issue 3 Not Upheld:

The Council noted that the advertisement had included statements as to the emissions and environmental aspects and limitations of SAF. In view of the transparency, the Council did not consider that the advertisement was in breach of the Code on the grounds raised in Issue 3 of the complaint.

Action Required: No further action required