Opportunity Green examines the legal risks of promoting ‘SAF’ across aviation’s alternative fuels supply chain and exposes the legal risk of using the umbrella term ‘sustainable aviation fuel’. 

London, 16 July 2025: A new legal briefing – Fuelling misconceptions: the legal risks of advertising ‘sustainable aviation fuel’ – launched today by climate change NGO Opportunity Green, outlines the growing legal, financial and reputational risks for actors across the aviation supply chain of using the term ‘sustainable aviation fuel’.   

The report highlights that ‘SAF’ is a vague, umbrella term that is used indiscriminately by the industry but which in reality includes a range of fuels – from biofuels to green hydrogen-derived e-fuels. These vary wildly in how environmentally friendly they actually are. This lack of clarity can mislead consumers and investors, and use of the term ‘SAF’ may therefore even break the law. While greenwashing concerns have traditionally focused on consumer law, the report also highlights the financial regulatory risks, warning that banks and industry investors are increasingly exposed to legal scrutiny under new financial rules. 

The report accordingly calls for airlines, financial institutions and other industry stakeholders to stop using ‘SAF’ as a catch-all term. This will avoid companies breaching their obligations under consumer protection and financial law and exposing themselves to potential anti-greenwashing legal action, fines, and reputational damage. 

Opportunity Green lays out four clear recommendations to ensure green labels are not misleading, deriving from analysis of anti-greenwashing rulings and regulatory guidance: 

1. Fuel producers, airlines and investors should not use the term ‘sustainable aviation fuel’. Most people will not understand that ‘SAF’ covers a wide range of fuels with very different climate impacts.  

2. Aviation stakeholders should instead use the term ‘alternative fuel’, supplementing with complete information about the fuel’s full lifecycle impact and aviation’s overall negative climate impacts. 

3. Airlines should not offer alternative fuel credit purchases to consumers as a viable option to offset the emissions of a flight. 

4. Financiers should not advertise biofuels as a green investment and must back up sustainability claims around alternative aviation fuels with robust evidence.  

Billions at stake 

The aviation industry looks set to raise billions to finance its transition in the upcoming decades – alternative aviation fuels could require $19bn–$45bn USD in capital expenditure by 2030 according to the World Economic Forum. This means that in turn the promotion of investments in alternative fuels, in particular biofuels, as “sustainable” by financial institutions could face growing legal scrutiny under financial law.  

The report urges financiers to heed the lessons from anti-greenwashing –  multi-million euro rulings and legal decisions against airlines* – and undertake appropriate due diligence into their ‘sustainable aviation fuel’ investment portfolios, particularly when these are advertised as such. As confirmed in the UK Financial Conduct Authority’s Anti-greenwashing Rule, firms must robustly evidence the environmental impact of the fuels they label as sustainable or risk investigation and enforcement action.  

Opportunity Green’s Legal Officer and author of the report, Olivia Moyle, says: 

“As alternative fuels go mainstream, regulators and courts have made it clear: green labels cannot mislead and should not be used as a shortcut to public trust. Precise terminology is critical: mislabelling fuels as ‘SAF’ without robust evidence risks misleading consumers and investors, breaching legal obligations and inviting legal challenge for greenwashing. Not all ‘SAFs’ are created equal – green claims must be properly substantiated in order to maintain trust, retain investor confidence, and ensure investment is directed to truly sustainable solutions.”  

ENDS 

Notes to editors 

The report Fuelling misconceptions: the legal risks of advertising sustainable aviation fuel is available to download here (link live on Wednesday 16 July). 

*Courts and regulators across Europe have repeatedly found airlines to be misleading and engaging in greenwashing practices under consumer protection law. For example:  

• Fossielvrij v KLM (2024) 

• VKI v Austrian Airlines (2023) 

• UK ASA Ruling against Virgin Atlantic 

The introduction of more stringent legislation (the EU’s Empowering Consumers Directive and the UK’s Digital Markets, Competition and Consumers Act) and the EU Commission’s ongoing investigation into 20 airlines’ greenwashing practices demonstrates that scrutiny and legal risk is growing for businesses advertising alternative fuels. 

UK financial law and regulation has also strengthened in recent months. As the UK Financial Conduct Authority’s Anti-greenwashing Rule came into force earlier this year, many parallels can be drawn between consumer protection law rulings and greenwashing risks on the financial market. This risk is not theoretical: In April, DWS was fined €25m and found to mislead investors about the sustainability and climate impacts of some of its funds. Similar legal investigations into Blackrock, ING and BNP Paribas show this is a growing trend and financiers must pay attention to how alternative fuels are advertised on the financial market. 

Opportunity Green is an NGO working to unlock the opportunities from tackling climate change using law, economics, and policy. We do this by amplifying diverse voices, forging ambitious collaborations and using legal innovation to motivate decision makers and achieve climate justice, with particular emphasis on the aviation and shipping industries.