The legal risks of advertising ‘sustainable aviation fuel’

July 2025: This report makes a clear case for altering the demand for shipping as a route to reducing GHG emissions and shows that even small differences can matter when it comes to reducing greenhouse gas emissions.

July 2025: This briefing examines ammonia’s potential as a cleaner shipping fuel, outlines its environmental and safety risks and offers policy recommendations to manage them effectively.

June 2025: This report examines how the revenues raised from the new IMO Net-Zero Fund measure could be distributed to maximise positive outcomes that support equity and justice, and offset the cost of maritime’s transition.

June 2025: A complete overview of the EU emissions trading system (ETS) for aviation, where it fails to regulate the sector and how policymakers can make it fit for purpose.

June 2025: This briefing urges States at the ICAO 42nd Assembly to effectively tackle aviation emissions. It outlines States’ obligations and practical steps to align aviation with a credible path to net zero.

March 2025: Our research reveals that the world’s 10 biggest public shipping companies top all-time high profits of $300bn in five years – but pay less than half the average tax rate. The problem is biggest in the largest and most profitable companies.

May 2025: A factsheet to understand what has been agreed at the International Maritime Organization (IMO) MEPC 83 in April 2025 to cut international shipping emissions.

May 2025: A full guide to the legal process for amending the MARPOL Convention at the IMO, and how the IMO’s Net-Zero Framework could become binding international law.

April 2025: This submission to the House of Lords’ Environment and Climate Change Committee emphasises the urgent need for a more coherent and ambitious approach to nitrogen pollution.

April 2025: This brief examines whether there is any need to create a separate legal instrument to adopt an economic measure at the IMO.

Jan 2025: Our submission to the HM Treasury consultation on Air Passenger Duty (APD) advocating for a raise in taxes on private jets.

Jan 2025: Our briefing sets out key recommendations for policymakers on reducing aviation’s contrail impact.

Nov 2024: Our legal briefing debunks widespread myths about the legal obstacles to taxing international aviation fuel.

Oct 2024: Our submission about shipping’s impact on the human rights to a healthy environment.

June 2024: OG and other NGOs call on ferry and train companies to amend UK to Ireland Sail & Rail tickets, and stop causing extra costs to customers and the climate.

May 2024: Opportunity Green wrote a submission to the UN Special Rapporteur on climate change about how ineffective access at the ICAO and IMO limits accountability for emissions reductions.

March 2024: This briefing identifies more than 30 climate change cases targeting the shipping sector to date and reflects on key developments.

March 2024: Opportunity Green and other organisations write an open letter to the UK government to extend an ECA in UK waters.

Jan 2024: How taxing the aviation sector could address the impact of loss and damage from the adverse effects of climate change on human rights.

Sept 2023: (Un)Sustainable from Ship to Shore reveals the extent to which the cruise industry is trying to gaslight the public into believing that fossil LNG is a climate solution when it is not.

Sept 2023: This report finds that all pathways to truly sustainable fuels for the shipping and aviation sectors require green hydrogen.

June 2023: We ask the International Tribunal of the Law of the Sea to confirm that the law of the sea obliges countries to decarbonise international shipping.

April 2023: How the International Maritime Organization can regulate the emissions from the full lifecycle of fuels for shipping.

Dec 2022: The International Civil Aviation Organization and the International Maritime Organization are violating international standards on transparency and citizens’ access rights.

Oct 2022: We shed light on the UK’s policy on green hydrogen and its failure to act on international shipping emissions.

Sept 2022:The UK has an obligation to act on greenhouse gases from the international maritime sector, outside the International Maritime Organization framework.

Sept 2022: With the launch of the Ports For People campaign, Opportunity Green and Pacific Environment set out how ports and local communities can take ownership of their transition to a climate-friendly future.

June 2022: International law does not provide any material restrictions on the measures the U.S. can directly implement on ships calling at its ports.

June 2022: We responded to the OHCHRs call for input on the promotion and protection of human rights in the context of climate change, in advance of MEPC 77.

Feb 2022: In this CE Delft report, written for the Dutch Ministry of Transport and Water Management, we perform legal analysis of potential avenues for the reduction of non-CO2 aviation emissions.

The implications from recent court rulings on EIAs for EU airport and port expansion. 

May 2025: Our policy briefing outlines the key challenges posed by AI-driven data centre growth and offers recommendations for government action.

March 2025: OG joins 28 NGOs endorsing a new report advocating for a green steel transition in Europe.

February 2025: Our response to the UN Special Rapporteur highlights the critical need to address the shipping and aviation sectors.

Jan 2025: OG and The Shift’s submission to the UN CESCR on its review of UK housing, decarbonisation, and economic, social and cultural rights.

Dec 2024: Our submission to the UN CESCR on its draft General Comment on economic, cultural and social rights.

Nov 2024: Our legal briefing debunks widespread myths about the legal obstacles to taxing international aviation fuel.

Oct 2024: Our submission about shipping’s impact on the human rights to a healthy environment.

Oct 2024: Our legal briefing on States’ responsibility to address international shipping and aviation emissions in their nationally determined contributions (NDCs).

Aug 2024: Our court filing against the EU Commission at the European Court of Justice for its decision to label highly polluting planes and ships ‘green’ in the Taxonomy.

July 2024: Opportunity Green’s legal analysis shows that the use of scrubbers on ships falls short of the requirements of MARPOL Annex VI due to harmful air pollution levels.

June 2024: Our latest legal briefing analyses the implications of the ITLOS advisory opinion on international shipping and aviation.

June 2024: Our latest briefing examines climate change litigation cases driving energy efficiency in residential buildings, recognising its impact both on reducing emissions and promoting social justice.

May 2024: In our latest legal submission, Opportunity Green responded to the Special Rapporteur on climate change’s call for inputs on access to information on climate change and human rights.

May 2024: OG and T&E explain why international aviation and shipping must be included in Aotearoa New Zealand’s 2050 climate target.

March 2024: OG asks the ICJ to confirm that States must do more to address the substantive climate impacts from international aviation and shipping.

March 2024: This briefing identifies more than 30 climate change cases targeting the shipping sector to date and reflects on key developments.

Jan 2024: Along with four other NGOs, Opportunity Green launches a legal challenge to the EU Commission's Taxonomy for sustainable activities

Nov 2023: Submission to the Special Rapporteur on the promotion and protection of human rights in the context of climate change.

June 2023: We ask ITLOS to confirm that the law of the sea obliges countries to decarbonise international shipping.

We call for robust national climate governance to foster national leadership in delivering the EU’s objectives on climate neutrality and the rule of law.

June 2022: The European Commission’s delegated act defining additionality and geographic and temporal correlation of RFNBOS goes beyond the legal authority the Commission was given.

Feb 2022: This analysis discusses whether and how the EU can pass on a carbon price to fuel suppliers rather than European households.

Feb 2022: We assess how countries can meet their obligation to reduce the climate impact of international shipping without conflicting with existing international law

Dec 2021: As the European Commission proposes adding shipping to the ETS, Opportunity Green considers the division of responsibility for compliance between ship owners and charterers.