Offsetting claims run into regulatory headwinds

The Advertising Standards Authority has upheld complaints against environmental claims by Qatar Airways and Eurowings, reinforcing the compliance risk facing companies that use carbon offsetting language in consumer and corporate marketing.

The rulings, both published on 15 July, form part of the regulator’s wider work on carbon offsetting claims in the air travel sector. They show that evidence of an offsetting programme may not be enough if an advert implies that a specific product, service, flight, or business activity has had its environmental impact fully neutralised.

In the Qatar Airways case, the ASA considered claims including “bulk offset the carbon emissions for your past and future flights” and “Travel consciously by offsetting your flight’s carbon footprint”. The airline said the ads promoted a voluntary carbon offsetting programme for corporate customers as part of its Beyond Business rewards scheme.

The ASA acknowledged evidence provided on the operation of the offsetting programme, including methodology and the retirement of verified carbon credits. However, it concluded that the evidence did not show the emissions from specific past or future flights would be fully offset or that the environmental impact of the flights was reduced.

The regulator told Qatar Airways not to state or imply that businesses or consumers could fully offset emissions from specific flights, or bulk offset emissions, unless it held suitably robust substantiation.

In the Eurowings case, the ASA challenged a Google advert that referred to “CO2 compensation” and stated that consumers could offset up to 100% of carbon emissions per flight. The regulator said the overall impression was that consumers could travel in a way that had a lower environmental impact because of the cited compensation and offsetting options.

The ASA told Eurowings to ensure future ads did not give a misleading impression of the impact caused by travelling with the airline, and not to imply that consumers could fully offset emissions from a specific flight without robust substantiation.

The rulings reach beyond aviation. Green claims increasingly sit at the intersection of marketing, ESG, legal, finance, and product teams. Companies are under pressure to show climate progress, while regulators are becoming more demanding about the evidence behind sustainability language.

Carbon offsetting is particularly sensitive because it can be used to suggest an immediate reduction in impact when the underlying activity still generates emissions. Offsets may support climate finance, but claims about neutralisation, compensation, climate-conscious travel, or reduced impact can mislead if customers interpret them as changing the environmental effect of the specific purchase.

Marketing teams are now dealing with a higher evidential standard. The test is not only whether a business has bought credits, supported a scheme, or followed a recognised methodology. It is whether the claim made to the customer accurately reflects what has been achieved, the limits of that achievement, the timescale, and the connection between the offset and the product being purchased.

The rulings also show that B2B claims are not immune. Qatar Airways argued that some ads were aimed at corporate users with a higher level of sustainability knowledge. The regulator’s approach indicates that business-facing environmental claims still require careful substantiation, especially where they may influence travel procurement, emissions reporting, or corporate sustainability positioning.

Greenwashing risk has become an operational compliance issue. The Competition and Markets Authority, ASA, FCA, and sector regulators are all scrutinising environmental language in different contexts. That creates a need for internal governance over claims before campaigns go live.

Sustainability teams may understand the limitations of offsets, legal teams may understand claims risk, and marketers may focus on clarity and engagement. Weak review processes can still allow simplified language to reach market without the evidential caveats needed to keep it accurate.

The airline rulings show the direction of regulation. Sustainability claims must be specific, evidence-led, and proportionate. Companies can still communicate climate initiatives, but broad reassurance around offsetting is increasingly exposed if the language outruns the underlying evidence.