Publications
July 2025
Fuelling misconceptions: the legal risks of advertising ‘sustainable aviation fuel’
Airlines, financiers and fuel producers risk legal action by using the misleading term 'sustainable aviation fuel' (SAF) – a vague umbrella term that covers fuels with vastly different environmental impacts.
Background
The aviation industry is responsible for at least 4% of historic global warming, with this figure potentially reaching 9% when considering the full range of climate impacts. As the sector continues to grow, it is estimated it will account for nearly a quarter of global CO2 emissions by 2050.
In response, the industry has promoted alternative fuels under the umbrella term 'sustainable aviation fuel' or 'SAF'. However, these fuels vary significantly in their actual environmental impact, and the absolute term 'sustainable' risks misleading consumers, investors and the general public.
What's covered in the report?
Fuelling misconceptions: the legal risks of advertising 'sustainable aviation fuel' outlines the growing legal, financial and reputational risks for actors across the aviation supply chain of using the term 'sustainable aviation fuel'. The report demonstrates that:
The term 'SAF' is legally problematic. It's a vague, umbrella term used indiscriminately by the industry that in reality includes a range of fuels with wildly different environmental credentials. This lack of clarity can mislead consumers and investors, and use of the term 'SAF' may therefore break the law.
Financial institutions face new regulatory risks. While greenwashing concerns have traditionally focused on consumer law, the report highlights that banks and industry investors are increasingly exposed to legal scrutiny under new financial rules.
Clear guidance exists to avoid legal liability. Our report provides recommendations derived from analysis of anti-greenwashing rulings and regulatory guidance to ensure green labels are not misleading.
The scale of the problem
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 the promotion of investments in alternative fuels 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. 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.
Our recommendations
Opportunity Green lays out four clear recommendations to ensure green labels are not misleading:
Stop using the term 'sustainable aviation fuel'. Fuel producers, airlines and investors should not use this term as most people will not understand that 'SAF' covers a wide range of fuels with very different climate impacts.
Use accurate terminology instead. Aviation stakeholders should use the term 'alternative fuel', supplementing with complete information about the fuel's full lifecycle impact and aviation's overall negative climate impacts.
Don't offer alternative fuel credits as offsets. Airlines should not offer alternative fuel credit purchases to consumers as a viable option to offset the emissions of a flight.
Back up sustainability claims with robust evidence. Financiers should not advertise biofuels as a green investment and must back up sustainability claims around alternative aviation fuels with robust evidence.
Download the full report below.