Complaint submitted to Advertising Standards Authority about misleading Ryanair emissions advert.

A complaint has been made to the Advertising Standards Authority (ASA) about an advert Ryanair has placed in newspapers saying it is “Europe’s lowest fares, lowest emissions airline” on the grounds that it is systematically misleading about the airline’s carbon emissions. While that may be true in terms of carbon emissions per seat kilometre flown, it is certainly NOT true for the airline as a whole. Ryanair is in fact now the 10th largest carbon emitter in Europe, on an assessment of power stations, manufacturing plants and airlines. Its emissions were around 10 million tonnes CO2 in 2018, up 6.9% on 2017.  The complainant says the “unqualified statements” in the advert combine to make the advert “comprehensively misleading as to the impact of both past and future expansion of low-cost air travel on carbon emissions, an expansion which was, and is still, being led by Ryanair.” 


Complaint submitted to Advertising Standards Authority about misleading Ryanair emissions advert.

The Ryanair advert:

People need to realise the misrepresentation that Ryanair is attempting, maybe as just the boldest of the aviation industry attempts to push back against increasing public concerns about its climate change impacts.  If you look at the Sunday Times 15 September 2019, bottom right of page 3 (and maybe other papers) you’ll see a Ryanair advert ‘Europe’s lowest fares, lowest emissions airline’. (Image above). There is a little YouTube video by Ryanair, peddling this nonsense too, at


The complaint submitted to the ASA is as follows:

“This advert is misleading in three extents:

– Its statement ‘While aviation is responsible for just 2% of carbon emissions, our industry is determined to play a leading role in reducing emissions’ misleads because it does not identify or qualify the geographical area in which aviation carbon emissions represent just 2% of the total. In fact this is the global proportion, whereas the European percentage (where Ryanair undertakes most of its activity) is 3% (see whilst in the UK (in which this advert is being published) it is 7% – see Department for Transport “Aviation 2050: the future of UK aviation”  December 2018, paragraph 3.77  at  (Para copied below)

Also note that whilst the advert sentence talks about ‘reducing emissions’ the last two sentences of DfT paragraph 3.77 note that UK aviation carbon emissions are likely to rise in the future, up to as much as 25% by 2050.

– Its statement ‘Ryanair has the lowest carbon emissions of any major airline – 66g CO2 for every passenger kilometre flown’ is misleading to the point of being factually wrong, because it fails to explain that the quantity of carbon emissions produced by an airline is derived from the amount of carbon per passenger kilometre (which the advert cites) multiplied by the quantity of passenger kilometres flown (which it does not). Because Ryanair carries the largest number of passengers in Europe over its very extensive route network, a quantity which is also rising, this results in Ryanair being identified in April 2019 as one of the 10 largest carbon polluters in Europe, and the only airline in that category.


– Its statement ‘Ryanair is committed to cutting our carbon emissions further …’ is misleading because its intention to increase its future passenger numbers may result in increased carbon emissions because the increase in passenger kilometres flown may outweigh a reduction in carbon per passenger kilometre.


 Para 3.77 from DfT’s   “Aviation 2050 The future of UK aviation”


UK aviation accounts for around 7% of the UK’s total greenhouse gas emissions, an increase from around 5% in 2005.56 International aviation’s carbon emissions currently account for less than 2% of total global emissions, but these could increase by two to four times between now and 2050.57 Aviation’s share of emissions is likely to continue to increase as other sectors, such as energy and manufacturing, decarbonise more quickly. This means that aviation could represent 25% of the UK’s greenhouse gas emissions by 2050.58  [Note 58: 58 Committee on Climate Change (2015): Advice on the fifth carbon budget] 



And a bit of history – 2007:


Ryanair’s green claims criticised by ASA

BBC     18.7.2007

Ryanair says it will defy the ASA and continue to use the figure

Ryanair has been ordered not to repeat an advertisement that played down the impact of aviation on the environment.

In a press campaign the airline claimed the airline industry “accounts for just 2% of carbon dioxide emissions”.

The Advertising Standards Agency (ASA) ruled it breached rules on truthfulness by not explaining the figure was based on global rather than UK emissions.

Ryanair claimed the ASA was attempting to suppress an accurate statement, which it would continue to use.

Ryanair’s claim that aviation made up 2% of CO2 emissions was based on global carbon dioxide emissions, the ASA said.

The UK government figures for domestic and international flights leaving the UK, put the figure at 5.5%.

“Because Ryanair had failed to make the basis of the 2% figure quoted in the ad sufficiently clear, it was likely to mislead,” the ASA said.

But Ryanair argued its 2% figure came from a UN report on climate change, and that it used a global figure because the issue was a global one.

The watchdog launched its investigation after receiving 34 complaints from the public.

‘Intellectually dishonest’

The European Environment Agency’s executive director, Professor Jacqueline McGlade, welcomed the ruling, saying that Ryanair had sought to “trivialise” the impact of aviation on the environment.

She described the airline’s approach to CO2 emissions as “disingenuous and intellectually dishonest”.

It is the second time this year that the carrier has got into trouble for misleading environmental claims.

In January it conceded, following a BBC investigation, that a claim it had cut its CO2 emissions by half in recent years was “a mistake”.

The ASA judgement on the Ryanair adverts is published today at

[1]  See ASA statement below


[3]  A sub-committee of Airport Watch

[4]  Tyndall Centre for Climate Change Research.  Decarbonising the UK.