The aviation sector is under increasing pressure to demonstrate genuine progress on sustainability. With the introduction of the EU Flight Emissions Label (FEL), airlines now have to make their emissions performance visible to passengers at the point of booking. While this creates opportunities for transparency and trust, it also introduces significant compliance risks. Without careful alignment between data, reporting, and communication, airlines risk accusations of greenwashing—damaging credibility with both regulators and the public.
The Nature of FEL Compliance Risks
1. Inaccurate Data Reporting
The FEL requires airlines to provide accurate data on fuel consumption, passenger loads, and lifecycle emissions. Any errors or shortcuts can lead to mislabeling, regulatory penalties, or reputational damage.
2. Overstating Sustainability Gains
Airlines may be tempted to exaggerate the impact of initiatives such as Sustainable Aviation Fuel (SAF) usage. Overstating SAF blending ratios or future commitments can easily be flagged as misleading.
3. Misuse of Voluntary Offsetting
While carbon offsets are still widely used in aviation, the FEL focuses on actual flight emissions. Suggesting that offsets improve FEL ratings could be seen as misrepresentation.
4. Inconsistent Label Display
The FEL must be visible across all sales platforms. If labels appear inconsistently—say on a website but not on partner booking engines—it undermines trust and compliance.
5. Passenger Misinterpretation
Even when data is accurate, unclear or overly complex communication can lead passengers to believe an airline is greener than it actually is. This “implied greenwashing” can be just as damaging.
How Airlines Can Avoid Greenwashing
Invest in Robust Data Systems
Airlines must ensure that fuel use, passenger data, and lifecycle emissions are tracked with accuracy and verified by independent auditors. Robust systems minimize the risk of errors.
Be Transparent About Methodologies
Clarity about how emissions are calculated builds trust. Airlines should make methodology details available through the secondary display of FEL data.
Link Claims to Verified Outcomes
Instead of making broad sustainability claims, airlines should connect messaging directly to verifiable outcomes—for example, “Our FEL shows reduced emissions on routes where SAF has been introduced.”
Train Staff and Partners
Compliance is not just about data—it is also about communication. Sales teams, partner agencies, and even customer service staff should be equipped with the right language to avoid overstatements.
Keep Passenger-Centric Language
Labels are designed for passengers. Explaining results in plain language ensures clarity and avoids any impression of hidden agendas.
The Business Case for Doing It Right
Avoiding greenwashing is not just about avoiding penalties—it’s about building long-term credibility. Airlines that take the FEL seriously stand to benefit from:
- Customer trust: Passengers reward airlines that communicate transparently.
- Regulatory confidence: Authorities are less likely to scrutinize carriers with a strong compliance track record.
- Competitive advantage: A credible FEL rating can differentiate airlines in an increasingly climate-conscious market.
VURDHAAN’s Expertise in FEL Compliance and Greenwashing Prevention
At VURDHAAN, we help airlines navigate the complex space where compliance, communication, and sustainability meet. Our expertise includes:
- Compliance risk assessments: Identifying gaps in FEL reporting and display obligations.
- Greenwashing safeguards: Developing clear, accurate messaging that aligns with verified data.
- Sustainable Aviation Fuel advisory: Supporting airlines in adopting SAF strategies that genuinely improve FEL scores.
- Stakeholder engagement: Helping airlines communicate with regulators, passengers, and partners in a transparent, consistent way.
For us, the EU FEL is not just a compliance exercise—it is a unique opportunity for airlines to turn transparency into trust. With the right strategy, airlines can avoid the pitfalls of greenwashing and instead build a reputation as leaders in sustainable aviation.