We’re filing complaints over cruise companies’ ‘green’ fuel claims. Here’s why…

It’s been an important week for us at Opportunity Green as we published our report, (Un)Sustainable from ship to shore, and filed complaints against the cruise industry’s systemic misleading advertising of fossil LNG as a ‘green’ fuel.

Our latest report, (Un)Sustainable from ship to shore, highlights how the cruise industry is advertising liquified natural gas (fossil LNG) as a climate-friendly fuel, when the science suggests it is anything but.

As a result of our investigation, we became particularly concerned about the potential for holidaymakers to be misled into believing that their cruise is sustainable through this advertising. So, we have filed a series of complaints to the Advertising Standards Authority (ASA) to try to get these adverts taken down.

What is fossil LNG, and why is it bad for the climate?

Due to a greater uptake of fossil LNG, methane emissions from global shipping increased by 150% between 2012 and 2018. Methane emissions by cruise ships in European Exclusive Zones increased fivefold between 2019 and 2022 for the same reason.

This rings huge alarm bells. Methane is an incredibly powerful greenhouse gas with climate impacts over 80 times greater than CO2 over a 20-year period. Until recently, it has been far less prominent than carbon in climate policy, but the devastating short-term, front-loaded climate impact of methane is incredibly worrying when recent weather events demonstrate the world is closer than we thought to tipping points.

Nevertheless, Cruise Lines International Association (CLIA), the world’s largest cruise industry trade association, has recently announced that 61% of new build capacity will rely on fossil LNG as primary propulsion. Key operators on the cruise market participate in this concerning trend – including Carnival Corporation & plc, MSC Cruises and Royal Caribbean Group.

Not only do these companies increasingly rely on fossil LNG as a shipping fuel, but they advertise fossil LNG as a climate-beneficial fuel to consumers. Advertising tactics include:

Our investigation raises concerns that the cruise industry’s fossil LNG adverts may constitute little more than greenwashing. In our new report, (Un)Sustainable from Ship to Shore, we collated and analysed dozens of these advertising claims. As a result of our findings, we also filed a series of complaints with the ASA.  

These adverts risk tricking holidaymakers into believing that cruise companies’ investments into fossil LNG constitute real climate action, when fossil LNG really is just another dirty fossil fuel.

The climate implications of using fossil LNG as a shipping fuel

What these cruise companies don’t tell us in their advertising is that fossil LNG consists primarily of methane. Which is, as already explained, a GHG with climate impacts over 80 times greater than CO2 over a 20-year period.

And while companies are quick to celebrate the carbon emissions savings of fossil LNG, research has shown that the lifecycle methane emissions associated with the use of fossil LNG in cruise ships actually lead to an overall increase in greenhouse gas emissions.

And it’s extremely concerning that the methane slip on board the vessel is particularly high for fossil LNG-powered cruise ships, due to the leaky engines they use.

Is this really greenwashing?

Essentially, greenwashing is where companies make false or misleading statements about environmental credentials. Greenwashing is mostly dealt with in law in terms of consumer protection, but in reality, it deceives a wide range of groups, from consumers to company investors. It causes confusion and, at its worst, enables companies to evade legitimate scrutiny of their activities.

How many of us have the scientific or technical understanding to really know how ‘environmentally friendly’ or ‘green’ the products we buy really are?

In recent years there’s been a rise in greenwashing litigation as consumers, civil society groups and regulators have started to hold companies to account for their climate commitments. In fact, greenwashing has been identified as one of the greatest emerging legal risks for companies globally and across all sectors.

The regulatory landscape governing green claims is complex and comprises domestic laws, supranational laws, non-binding guidance documents, complementary self-regulatory codes, and environment-specific codes.

As these frameworks are developing quickly, on all fronts, there is clear tendency from regulators to crack down on misleading green claims.

In the United Kingdom, the Competition Markets Authority (CMA) has opened an investigation into supposedly ‘green’ claims of the fashion sector. And the ASA has banned greenwashing adverts across sectors such as energy, buildings and heating, finance and transport.

Earlier this year, the ASA called out Lufthansa for its misleading advertising, claiming that the airline’s green initiatives were protecting the world. The ASA made clear that despite what Lufthansa’s ads suggested, there are currently no environmental initiatives or commercially viable technologies in the aviation industry which would substantiate such absolute green claims.

And while this may be a hard pill to swallow, we think the same applies to the cruise industry – there is simply no such thing as a sustainable cruise today. And fossil LNG certainly doesn’t provide it.

Challenging the narrative of ‘natural’ gas

The promotion of natural gas as a climate solution is expected to be one of the key issues that we will see addressed by legal interventions tackling greenwashing. In fact, climate-related claims around natural gas have already started to be challenged.

A prominent example is Transport & Environment’s successful legal challenge of oil giant ENI’s advertising claims which touted natural gas as “green” and ended in a €5 million fine.

Another example is Client Earth’s challenge of BP’s advertising claims which described gas as “cleaner burning”. BP ended up withdrawing their advertising campaign shortly after the complaint.

Fossil LNG is no climate solution

The science is clear: it’s high time to Say No To LNG.

The United Nations body for assessing climate science, the Intergovernmental Panel on Climate, has stressed that natural gas-based fuels are inadequate to meet decarbonisation goals for shipping.

In a seminal report from 2021, the World Bank spoke out against the use of fossil LNG as a transitional fuel and concluded that fossil LNG had, at best, a limited role to play in the transition of the shipping sector. In fact, the World Bank warned that ‘there are significant risks that speak against LNG as a transitional fuel.’

As confirmed by the International Chamber of Shipping, zero emissions can only be achieved with genuine zero CO2 fuels and propulsion technologies. Fossil LNG is not one of these fuels.

Our recommendations to the cruise industry

Following our analysis of the cruise companies’ supposed ‘green’ claims around fossil LNG that identified a real risk of them being misleading to consumers, our report concluded with recommendations for the cruise companies:

  • Cruise companies should stop advertising fossil LNG as a climate solution which risks misleading consumers as to the true sustainability of their holiday.

  • Cruise companies that have misleadingly advertised the climate benefits of fossil LNG should remove such advertisements.

  • Cruise companies should stop investments into climate-damaging fossil LNG as a purported climate solution.

  • Cruise companies should back their net zero pledges with credible transition plans which include investments into real zero emissions solutions supported by the best available science.

Read our report (Un)sustainable from ship to shore and our accompanying press release to find out more.

Isabela Keuschnigg

Isabela is the Legal Officer at Opportunity Green.

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