Ryanair’s adverts claiming it is Europe’s lowest emissions airline have been banned after the Advertising Standards Authority (ASA) ruled there was not enough evidence to substantiate the claim.
The budget airline’s ads, which include its new slogan: ‘Europe’s Lowest Fares, Lowest Emissions Airline’, were part of a wider campaign to position itself as the environmentally conscious consumer’s airline of choice.
However, the ASA received complaints about its press, TV and radio ads, including from a consultant in energy, transport and sustainable development who challenged whether the claims “Europe’s … Lowest Emissions Airline” and “low CO2 emissions” could be substantiated.
And the ad regulator ruled that the adverts were “misleading” despite acknowledging that they “would be understood relatively” by consumers.
The ASA did accept that Ryanair’s calculations of its CO2 per passenger, which include factors such as seating density and air traffic, were sufficient, however it was “concerned” the calculations were not fully transparent. It stated that there was “insufficient” evidence to demonstrate that Ryanair was the lowest carbon-emitting airline even on the basis of that metric.
Ryanair defended the campaign saying: “We are both disappointed and surprised that the ASA has issued this ruling given that Ryanair fully complied with advertising regulations, engaging with regulators and providing documentation that fulfilled all the substantiations needed.”
It added that it “provided the appropriate regulatory information” including data from independent organisations Eurocontrol and Brighter Plane.
However, the ASA found that the Eurocontrol chart, which scored Ryanair fifth for CO2 emissions out of 27 airlines, was insufficient. The implication was that by dividing the emissions by the number of passengers, Ryanair would have the lowest emissions per passenger. However, there were other airlines on the Eurocontrol chart that had CO2 emissions which also appeared low relative to their share of air traffic (and therefore similar to Ryanair’s).
In addition, the Brighter Planet chart, which ranked Ryanair as top of the overall airline efficiency rankings for CO2 per passenger mile, was dated 2011. In addition, some well-known airlines did not appear on the chart, so it was not clear whether they had been measured.
Issues across media formats
That ASA had issues with almost every format Ryanair used to explain its low emissions claim.
Its print ads including the wording: “Everybody knows that when you fly Ryanair you enjoy the lowest fares. But do you know you are travelling on the airline with Europe’s lowest emissions as well?” and “Ryanair has the lowest carbon emissions of any major airline – 66g CO2 for every passenger kilometre flown. This is because we have the youngest fleet of aircraft (average age six years), the highest load factors (97% of seats filled) and newest most fuel efficient engines”.
The print ad compared Ryanair against four other airlines, which the airline said fell within the definition of a ‘major airline’. However, there is no commonly recognised definition of a major airline.
The ASA noted that consumers would understand it simply to mean those airlines they had heard of, particularly given that the headline claim gave no indication that the comparison was not market-wide and had failed to mention seating density.
In TV and radio, Ryanair’s ads both said: “Fly Ryanair. Europe’s low fare, low CO2 emissions airline from just £14.99. Book Ryanair today”, with the radio ad noting it was out of 27 airlines.
Neither of these gave any information on the metric used to measure emissions, how that was calculated or the role of seating density in that calculation.
The ruling is a blow to Ryanair, which has centred its brand positioning around its low emissions, alongside a focus on price as it looked to appeal to environmentally aware consumers, as well as those after cheap flights.
Speaking to Marketing Week in November, Ryanair’s CMO Kenny Jacobs said: “We need to communicate with customers that you can go from British Airways to Ryanair and halve your emissions. That’s the type of message that we realise we need to get across to people.”