Stansted Airport Watch submits response to CMA consultation on greenwash; examples from Stansted and Ryanair

The Competition and Markets Authority (CMA), which regulates business behaviour, has finally stepped in to try to end ‘greenwashing’ and has asked for evidence. Greenwashing is where businesses make dubious claims in an attempt to boost their environmental credentials, and thus sell more product. The CMA consultation ended on 16th July. Greenwashing is all too common in the aviation industry and Stansted Airport Watch (SAW) submitted detailed evidence to the CMA relating to both Stansted Airport and Ryanair. Some of the examples of dubious claims by the airport are that it claims to be “carbon neutral”, but this conveniently ignores the carbon emissions from the aircraft (hugely higher than emissions by the airport itself). It also relies of “offsetting”, so making payments to some carbon reduction activity elsewhere, while itself continuing to emit. Ryanair has made a number of claims about being “green”, such as claims to be Europe’s “cleanest, greenest airline” but this has been ruled against by the Advertising Standards Authority, for being misleading (February 2020).


Give Greenwash the Red Card

19th July 2021

Stansted Airport Watch press release

The Competition and Markets Authority (CMA), which regulates business behaviour, has finally stepped in to try to end ‘greenwashing’ and has asked for evidence. Greenwashing is where businesses make dubious claims in an attempt to boost their environmental credentials.

Greenwashing is all too common in the aviation industry and, last week, Stansted Airport Watch (SAW) submitted detailed evidence to the CMA relating to both Stansted Airport and Ryanair.

Stansted Airport:

Stansted Airport is the largest single source of carbon dioxide (CO2) emissions in the East of England and yet it constantly boasts that it has achieved ‘carbon neutral’ status. How can that be?

The answer lies in three clever tricks of the PR trade:

The ‘carbon neutral’ claim only applies to the airport buildings and airside vehicles but these two elements account for just 1% of the airport’s emissions. The other 99% is ignored – i.e. the aircraft emissions (about 90%) and the emissions from the road traffic taking passengers and freight to and from the airport (about 9%).

Even that 1% is not truly carbon neutral. The airport relies on “offsetting” to magic away CO2 emissions. An example of offsetting would be to make a donation to help protect a peat bog on the Yorkshire Moors. However, this does not stop the airport CO2 going into the atmosphere and contributing to climate change.

In trumpeting its “prestigious” award for achieving ‘carbon neutral’ status, Stansted Airport conveniently failed to mention of the fact that the award was given by ACI, the airports’ trade association, part financed by Stansted Airport. It’s a case of airports marking their own homework.


Ryanair is also adept at greenwashing. It claims to be Europe’s “cleanest, greenest airline” but, according to the European Commission, in 2019 Ryanair was responsible for emissions of 10.5 million tonnes of CO2, more than any other airline in Europe. In fact, Ryanair was the only airline listed on the Commission’s league table of Europe’s top ten polluters (it was ranked 7th).

In 2020 the Advertising Standards Authority (ASA) investigated Ryanair’s claims to be “Europe’s Lowest Emissions Airline” and to have “low CO2 emissions” and concluded that the claims were misleading. The advertising campaign which made these claims was banned and Ryanair was told by the ASA to ensure that when making environmental claims, it had adequate evidence to substantiate them, and also to ensure that the basis of those claims was made clear.

Stansted Airport Watch Chairman, Brian Ross, commented: “The aviation industry knows full well that its CO2 emissions are a major contributor to climate change but it uses clever PR – greenwashing – to create the impression that aviation is environmentally friendly. It’s like the claims made many years ago that smoking is healthy. Eventually the truth comes out.”



SAW’s submission to the Competition and Markets Authority is available on request from the Campaign Office (see below).


Brian Ross, Chairman: 01279 814961; (M) 07850 937143
SAW Campaign Office: 01279 870558;


‘Green’ claims: CMA sets out the dos and don’ts for businesses

The CMA has set out its views on the types of misleading environmental claims made about products that could break the law.

Last year, the Competition and Markets Authority (CMA) announced that it was investigating the impact of green marketing on consumers, in line with its annual plan commitment. As part of this, the CMA recently led on an analysis of websites – alongside other global authorities – which found that 40% of green claims made online could be misleading.

The CMA is now seeking views on draft guidance for businesses about ‘green’ claims. This is based on a careful review of how these claims are being made and how people respond to them. It explains the best way for businesses to communicate their green credentials, while reducing the risk of misleading customers.

This direction comes at a time when more than half of UK consumers take environmental considerations into account when buying products.

In particular, the proposed guidance sets out 6 principles that environmental claims should follow.


  • must be truthful and accurate: Businesses must live up to the claims they make about their products, services, brands and activities
  • must be clear and unambiguous: The meaning that a consumer is likely to take from a product’s messaging and the credentials of that product should match
  • must not omit or hide important information: Claims must not prevent someone from making an informed choice because of the information they leave out
  • must only make fair and meaningful comparisons: Any products compared should meet the same needs or be intended for the same purpose
  • must consider the full life cycle of the product: When making claims, businesses must consider the total impact of a product or service. Claims can be misleading where they don’t reflect the overall impact or where they focus on one aspect of it but not another
  • must be substantiated: Businesses should be able to back up their claims with robust, credible and up to date evidence



The CMA is inviting views on its guidance and is particularly keen to hear from anyone who buys or sells products which claim to be eco-friendly, including whether any further information is needed to help companies comply with the law.

The consultation will run until 16 July 2021, with the aim of publishing the final guidance by the end of September 2021. More information can be found on the CMA’s Misleading environmental claims web page.

Notes to editors.

  1. The key piece of consumer protection legislation relevant to the CMA’s guidance is the Consumer Protection from Unfair Trading Regulations 2008 (CPRs). The CPRs contain a general prohibition against unfair commercial practices and specific prohibitions against misleading actions or misleading omissions.
  2. The statistic that “half of UK consumers take environmental considerations into account when buying products” is taken from a 2014 European Commission Market Study.
  3. Related figures and statistics on this topic can be found in the CMA’s ‘Making environmental claims: a literature review’.

… and it continues ….



See earlier:

ASA rule against Ryanair ad (greenwash) claim to have the lowest airline CO2 emissions

Ryanair has been accused of greenwashing after the UK Advertising Standards Authority (ASA) banned an ad campaign, that tried to make out  the airline has the lowest CO2 emissions of any major airline in Europe. It has been ordered to withdraw the misleading claims about its “green” credentials. Ryanair is in fact one of the top 10 carbon emitters in the EU, due to the number of flights.  Ryanair probably has lower CO2 per passenger kilometre than many other airlines, as it has newer planes, and crams its planes full. But its rapid growth has meant its CO2 increased by 50% between 2013 and 2019. The ASA pointed out failings in the way Ryanair compared itself to other airlines, to make its carbon claims; it did not include all airlines or seating density; it did not substantiate its claims.  The growth of Ryanair, and of air travel in general, in Europe has been due to the sector paying no jet fuel tax, making flying artificially cheap. The CO2 emissions of all flights departing from EU airports have grown from being 1.4% of total EU emissions in 1990 to 3.7% today.



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.”

The Ryanair advert:



Advertising Standards Authority finds Heathrow advert about increased trade breaches their code and is ‘misleading’

In October 2014 about 13 people send in official complaints to the Advertising Standards Authority, on claims being made by Heathrow in its adverts. The ASA looked at 7 different complaints, and considered that 6 passed their standards. However, on the claim by Heathrow in its ads headed:”Expand Heathrow and its’s the economy that takes off” the statement “Direct flights to long-haul destinations build twenty times more trade with them than indirect flights” was found to breach the ASA code. The ASA say the claim was not adequately substantiated and that the ad therefore breached the Code, both by being misleading and by not having proper substantiation. The ASA say the advert “must not appear again in its current form.” They have told Heathrow “to ensure that they held robust substantiation for absolute claims made in their future advertising.”  The ASA ruling also says the claim was presented as objective facts rather than an educated assumption and that Heathrow’s own report “One Hub or None”itself cautioned that direct flights would not automatically lead to more trade and that multiple factors could influence the amount of bilateral trade.

Does Heathrow advert implying a small girl needs a 3rd runway, for her future, meet Advertising Standards?

ASA took a long time to consider this one, but finally did not decide against it.