EU Enforcement Action: 21 Airlines Commit To Reform Environmental Claims — What Aviation And Non-Aviation Businesses Should Know

On November 5, 2025, the European Commission (Commission) announced that 21 airlines committed to modifying their environmental marketing practices after EU consumer authorities alleged several common environmental claims could mislead passengers. The airlines agreed they will not claim that paying extra to fund climate protection projects or the use of alternative aviation fuels can directly neutralize or reduce emissions on an individual flight. In addition, the airlines committed to tighter substantiation, clearer disclosures, and more transparent CO₂ calculators, particularly as they relate to their use of sustainable aviation fuels (SAF). National consumer authorities will monitor implementation and may enforce against carriers that fall short.

Although the Commission's action targets EU airlines, U.S. airlines should review their marketing in the EU accordingly. In addition, the EU's action provides important insight into how EU authorities view environmental marketing claims more generally. Companies in other sectors should review their environmental marketing claims in light of this action, particularly if they have programs that give consumers the option to pay extra fees to fund the use of alternative fuels or support projects that offset emissions.

Legal Framework & Enforcement Posture

The Commission's announcement follows a coordinated review by the Consumer Protection Cooperation (CPC) Network, a network of authorities responsible for enforcing EU consumer protection laws. The CPC Network can take action under the Consumer Protection Regulation to address cross-border issues at the EU level in coordination with the Commission.

In addition to announcing the commitments from the 21 airlines subject to the review, the Commission also published a table tracking each airline's commitments and timelines; authorities will verify timely implementation and pursue enforcement, if needed. To ensure fair competition and a level playing field in the aviation industry, the Commission's announcement states that the CPC Network will also assess the practices of other airlines operating in the Single Market, and, where necessary, require the same commitments.

The CPC's action stemmed from an alert filed by BEUC (representing consumer organizations across the EU) in June 2023, pursuant to the Consumer Protection Regulation, alleging that 17 European airlines misled consumers by claiming "green fees" would render their flights sustainable and, more broadly, by implying "flying is sustainable." The complaint alleged that these claims constitute infringements of Directive 2005/29/EC (the Unfair Commercial Practices Directive - UCPD).

The UCPD harmonizes national laws governing business-to-consumer practices in the internal market and prohibits unfair commercial practices (Article 5), misleading actions (Article 6), and misleading omissions (Article 7). The European Commission's Guidance Notice on the interpretation and application of the UCPD, though not legally binding, is intended to clarify and facilitate its proper application, and includes guidance on which environmental claims may be considered misleading.

What the 21 Airlines Committed to Change

• Clarify that a specific flight's CO₂ emissions cannot be neutralized, offset, or directly reduced by optional passenger payments for climate projects or alternative fuels.
• Use "sustainable aviation fuel" (SAF) terminology only with appropriate clarifications and substantiation.
• Avoid vague "green" language or implicit environmental claims.
• Provide more detail when stating future climate goals (e.g., net-zero): include timelines, achievable steps, and the types of emissions covered.
• Display CO₂ calculations clearly and transparently.
• Support claims with sufficient scientific evidence.

Why This Matters in Aviation and Beyond

Although this example targets airlines, it signals how EU enforcers expect environmental marketing to be framed across sectors:

1. Claims that payment of fees will render products/services "Carbon-Neutral" or "Sustainable" Require Rigorous Clarification and Substantiation. The CPC's scrutiny of pay-to-offset schemes may serve as a warning to other industries that sell add-ons implying immediate neutrality.
2. SAF and similar "transition" claims need precise context. Claims about cleaner inputs (e.g., SAF) should avoid implying one-for-one emission reductions for a specific transaction and must be properly qualified.
3. Aspirational goals must be anchored in plans. Claims regarding net-zero or carbon-neutral goals should include timelines, milestones, scope clarity (Scopes 1–3), and methodologies.
4. CO₂ calculators may be perceived as marketing claims. If you publish route- or product-level emissions figures, expect scrutiny of assumptions, data sources, and presentation.
5. EU coordination is accelerating. This airline action follows earlier EU-level probes and national rulings that have tightened the bar on "sustainable flight" messaging.

Practical Next Steps For EU-facing Marketers

• Inventory – and revise if appropriate – green claims and map each to evidence (testing or internationally recognized methodologies), consistent with UCPD guidance and the evolving landscape of green marketing law at the EU-level (e.g., the Empowering Consumers Directive and the pending Green Claims Directive) and member-state level.
• Avoid using vague buzzwords ("eco-friendly," "green," "sustainable") unless defined and substantiated, in alignment with EU law.
• Train relevant internal teams (e.g., marketing, sustainability, and legal) on EU marketing laws, guidance, and prior decisions affecting green marketing claims and set up pre-clearance for sustainability messaging.
• Continue to closely monitor the rapidly evolving legal and policy developments in green marketing, not just in the EU but in other jurisdictions as well. (see, e.g., Canada Issues Guidelines on Civil Greenwashing Claims One Year After Amendments to the Competition Act).

What to Watch Next

• Whether national authorities or the CPC Network widen their focus to other sectors
• Continued negotiations over the finalization of the Green Claims Directive and national regulation and guidance on environmental claims and green marketing.
• Emerging case law and consumer-protection actions in European jurisdictions targeting broader "greenwashing" tactics, including the use of sustainability labels, "eco-friendly" branding, and offset claims.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.