ANALYSIS
Complaint filed with the ACCC to investigate Qantas’ misleading sustainability and net zero claims.
Australia’s national carrier is potentially making false claims about what it means to ‘fly carbon neutral’ and may be misleading Australians on their climate credentials.
Analysis by Claire Snyder & Chris Cooper
Climate Integrity, in partnership with the Environmental Defenders Office, has undertaken an analysis of Qantas’ net zero and sustainability claims, marketing materials and relevant disclosures, assessing the credibility of the company’s claims. As a result, Climate Integrity has filed a complaint with the consumer watchdog requesting they investigate Qantas for its potentially misleading sustainability and net zero claims.
The complaint to the ACCC comes following increased scrutiny on the aviation industry, with Dutch Courts ruling earlier this year that KLM made misleading claims to consumers, similar to Qantas' sustainability messaging. The KLM court case has spurred broader sweeping regulatory action of 20+ airlines, currently underway by the EU Commission.
Flying is a heavily polluting activity and one of the most emissions-intensive forms of travel. Qantas and the aviation industry are heavily reliant on fossil-fuels long term and contribute significantly to greenhouse gas emissions, which the IPCC projects will lead to 3.2ºC of warming.
Qantas’ marketing materials present the company as a sustainability leader on the path to net zero by 2050, in line with the Paris Climate Agreement, but Qantas’ claims are not backed up by credible targets or substantiating strategies. As such, Qantas sustainability and net zero by 2050 representations are potentially misleading.
Consumers should be able to make informed decisions cognisant of the true emissions impacts of flying. A single long-haul flight can produce a greater amount of CO2 emissions than the total recommended average annual footprint per person in 2030 - if we’re to limit global temperature increase to 1.5ºC as stated in the Paris Agreement temperature goals.
Deceptive or misleading sustainability representations are illegal under Australian consumer law. Greenwashing creates a false sense of progress and reduces the urgency for the necessary action to prevent further worsening climate impacts.
“
Consumers and shareholders are increasingly conscious of their climate impact, and deserve the right to make informed decisions. Qantas is a trusted household name in Australia, and it should not mislead customers and shareholders into thinking Qantas products and services are more sustainable than they really are.”
Claire Snyder
Director, Climate Integrity
Aviation’s Net Zero Dilemma
Aviation is a ‘hard-to-abate’ industry, and there are limited viable decarbonisation strategies available to airlines. However there are multiple credible sectoral pathways that Qantas and other airlines should be aligning their net zero plans with, each of which detail what is required to ensure air travel can continue into a net-zero future.
These pathways and targets, such as those recommended by the International Energy Agency (IEA) and the Science-Based Targets Initiative (SBTI), acknowledge the need for leadership and action from both airlines and Government. Qantas must be transparent about the challenges it faces to decarbonise and deliver a credible transition plan that uses all available solutions.
The components of a credible net zero plan for airlines, requires a broad set of actions including:
-
Airlines must set short-, medium- and long-term absolute emissions reduction targets and, where appropriate, relative emissions reduction targets across their value chain that are at least consistent with the latest IPCC net zero greenhouse gas emissions modelled pathways that limit warming to 1.5°C. Targets must cove all scopes and must account for all greenhouse gas emissions (based on internationally approved measures of warming effects) and include separate targets for material non-CO2 greenhouse gas emissions.
-
Of the emissions reductions in transport by 2050, nearly 80% come from measures to manage passenger aviation demand. The IEA sectoral pathway demonstrates that alongside these other changes, demand management and mode switching (shifting from aviation to rail for passengers and freight for example) can lead to a 50% reduction in emissions from aviation in 2050 - all while reducing the number of flights by only 12%.
-
Carbon removals have a limited role to play in aviation net zero plans to counterbalance truly residual emissions, as modelled in credible, Paris-aligned pathways such as the IEA. However they should not be used to offset current fossil fuel emissions where those emissions are outside Paris-aligned decarbonisation trajectories
-
Biofuels, or “Sustainable Aviation Fuel” as the industry likes to call them, are a critical strategy for decarbonising aviation, with the IEA modelling the need for around half of all aviation fuel in 2050 to be ‘low emission’ or from liquid biofuels.
-
Continuous improvements in the fuel economy and efficiency of planes and operations. However, efficiency improvements provide minimal contribution to emissions reduction that is largely negated by the increase in demand that such improvements can generate.
Qantas regularly concedes the challenge of decarbonising its practices and the industry as a whole, while simultaneously claiming to have a credible and achievable plan to achieve its targets. The company has not disclosed which credible sectoral pathway its plan is aligned with, and the available disclosures appear to lack alignment with any credible pathway.
Qantas’ problematic net zero claims
Qantas has committed to a net zero by 2050 target, and regularly and boldly states its support for the Paris Agreement. Consumers would be forgiven for believing that Qantas is on a credible pathway to net zero, however the company’s net zero and sustainability claims are not sufficiently substantiated by the company’s disclosures. In this way, Qantas is failing to provide consumers and investors with the necessary information to assess and verify its claims.
Climate Integrity’s complaint to the ACCC outlines Qantas’ potentially misleading messaging and marketing materials, with a focus on the inability of Qantas to substantiate the claims. The complaint highlights a number of statements from Qantas that together form two (mis-)representations Qantas is making to consumers:
Sustainability Representation: that Qantas’ services are sustainable and do not have a significant adverse environmental or climate impact.
This is likely to mislead or deceive consumers because Qantas’ repeated use of the vague and broad term ‘sustainability’ is incongruous with its current and likely future emissions given its long term reliance on fossil fuels. And Qantas’ ‘Fly Carbon Neutral’ option likely misleads consumers into thinking that their flight is ‘sustainable’ and makes no significant contribution to climate change.
Net Zero Representation: that Qantas has a Paris-aligned net zero plan.
This is likely to be misleading or deceptive because Qantas has not disclosed a science-aligned, credible methodology required for consumers to substantiate alignment with their stated commitment to the Paris Agreement. The representation implies that Qantas has a reasonable basis for expecting to achieve net zero emissions by 2050, and has disclosed sufficient substantiating information to enable informed decision making by consumers.
Key Facts:
CO2 emissions derived from the global aviation sector have contributed around 4% to the earth’s global warming to date. Alarmingly, that percentage is expected to rise, with the International Civil Aviation Organisation (ICAO) forecasting aviation emissions could triple by 2050, compared to 2015.
In 2024, Qantas reported that it emitted a total (Scope 1, Scope 2 and Scope 3) of 17.6 million tonnes of carbon dioxide, which is equivalent to nearly 4% of Australia’s total annual CO2 emissions.*
In 2022, it was reported that around 11 per cent of Qantas customers pay extra to offset their flight emissions - the most successful carbon offset scheme of any airline, thanks to a marketing campaign which incentivised offsetting with bonus Qantas points.
In 2022, the carrier reported it had offset 3 million tonnes of carbon since 2007. To put that in perspective, in 2024 Qantas emitted 17.6 million tonnes of CO2.
The Australian Senate recently passed mandatory climate reporting laws and last month, ASIC released its report on actions taken to deter greenwashing misconduct
A single long-haul flight can produce a greater amount of CO2 emissions than the average annual target footprint per person in 2030, required for limiting the maximum temperature increase to 1.5ºC as stated in the Paris Agreement temperature goals.
*Qantas’ 2024 report states that it emitted 17,610,900 tonnes of CO2 globally. This is equivalent to 4% of Australia’s total annual CO2 emissions (440,200,000 tonnes). Please ensure this statement clarifies ‘equivalent to’, not ‘contributing to’. Qantas is not responsible for 4% of Australia’s annual carbon emissions – because its domestic aviation emissions are counted in Australia while international aviation emissions are accounted for separately as part of Australia’s participation in ICAO
Our analysis of Qantas’ net zero and sustainability claims informs a number of issues outlined in our complaint to the ACCC, explaining why these representations, taken together or individually, may be misleading and/or deceptive.
-
As outlined in our Net Zero Integrity report, Qantas’ disclosures on its net zero targets and strategies do not align with the Paris Agreement, the IEA sectoral pathway, nor the UN HLEG criteria for coverage or level of ambition. Qantas has not disclosed any robust methodologies for its target setting nor how its plan is substantiated by disclosing alignment with established, credible aviation decarbonisation pathways.
-
Qantas published its Climate Action Plan in March 2022, along with additional details on emissions reductions initiatives in its 2023 and 2024 Sustainability Reports. These disclosures are high-level and vague, and do not adequately substantiate Qantas’ plan for reducing emissions to meet its net zero targets. Qantas’ Climate Action Plan involves initiatives under three ‘pillars’ to help meet its emissions reduction targets:
Sustainable operations: upgrading the fleet, including a focus on fuel efficiency;
Sustainable Aviation Fuels; and
Carbon markets: passengers can voluntarily contribute to nature-based solutions.
The Climate Action Plan includes concrete actions but only the high-level pillars are linked to targets with broad estimates of expected reductions to be achieved from each pillar. Broad allocation of capital is described, but not detailed allocation to specific initiatives with a link to expected emissions reductions.
-
The IEA states that demand management in the aviation sector is critical to achieving the goals of the Paris Agreement. The IEA net zero by 2050 pathway states that nearly 80% of emissions reductions in transport in 2050 need to ‘come from measures to reduce passenger aviation demand’. This management of aviation demand is required because of the ‘scarcity of commercially available options to eliminate all emissions’ from aviation. The IEA projects that a failure to manage aviation demand would lead to >3°C of global heating, seeing parts of the world becoming uninhabitable for humans, which is also not in the interests of the aviation industry.
There is no indication that Qantas plans to manage consumer demand in line with recognised net zero pathways. Instead of opting for the ‘urgent and deep’ emissions reductions that are required, Qantas is aiming for growth both in its business plan and, according to research by InfluenceMap, alongside active lobbying in support for SAFs, has lobbied against meaningful aviation regulations through membership in industry organisations such as the International Transport Association (IATA), Business Council of Australia (BCA), Chamber of Minerals and Energy of Western Australia (CME), and Airlines for Australia & New Zealand (A4ANZ).
Qantas’ ambition to expand its business and flights is clear from its ‘plans to grow by creating up to 8,500 operational roles in Australia by 2033 to support new aircraft and additional flying', as outlined in its investor materials. With Project Sunrise, Qantas is also expanding into ultra-long-haul flights which are less fuel efficient, more carbon intensive, and misaligned with all credible net zero pathways. Qantas further incentivises increased travel through its Green Tier frequent flyer program. The program, launched in 2022, offers rewards to frequent flyers including ‘digital recognition’, access to ‘exclusive sustainability events and experiences’, bonus Qantas Points and Status Credits, or the option for ‘Qantas to offset 3 tonnes of carbon on your behalf’. This has the potential to misleads consumers into believing that increasing their travel with Qantas, alongside purchasing other ‘sustainable’ Qantas products like hotels and wine, will have no or limited impact on the climate.
-
Sustainable aviation fuels refer to two types of non-fossil aviation fuels: synthetic fuels and biofuels. Synthetic fuels, also known as e-fuels, can be produced using electricity and CO2, which still involves burning fossil fuels. Biofuels are derived from organic materials such as waste and surplus crops and used cooking oil.
Qantas appears to rely heavily on SAFs to substantiate the Net Zero Representation. On its ‘Sustainable Aviation Fuel’ webpage, Qantas describes SAF as ‘central to achieving our interim targets and net zero by 2050 goal’ and ‘the only viable technology/decarbonisation option available’ for reducing emissions from long-haul routes, which constitute the majority of Qantas’ carbon footprint.
Qantas has made promising and significant investments in the development of biofuels, which are central to achieving their net zero goals. However, there are currently many limitations that prevent SAF from being implemented at a commercial scale or as a feasible net-zero measure - see our SAFs explainer for more detail on the limited emissions reduction potential, availability limits, high costs, and infrastructure challenges.
-
Qantas offers customers a ‘Fly Carbon Neutral’ option at the point of purchase, stating that doing so supports ‘accredited projects that offset your carbon footprint’. On the ‘Fly Carbon Neutral’ page on its website, Qantas displays ‘Protect our Planet’ in bold as one reason to offset flights, stating ‘By choosing to Fly Carbon Neutral you can help support local communities as well as take action on climate change’. As further detailed in our explainer, this representation of the impact of Qantas’ carbon offsets is likely to mislead consumers into believing that opting in to 'Fly Carbon Neutral’ and offset their flight means their flight is ‘sustainable’ and makes no significant contribution to climate change.
-
Qantas’ ‘sustainable operations’ pillar refers to ‘reducing emissions by optimising fuel burn through flying and engineering procedures, airspace design and management, aircraft performance and flight planning’. However, efficiency improvements alone will not result in an overall reduction in emissions and offer limited potential for further gains. Historically, such improvements have only spurred more growth, as increased efficiency makes flights cheaper, thereby boosting demand. This increase in demand negates any CO2 emissions reductions through improved efficiency measures.
Qantas previously had a stated aim to improve fuel efficiency by an average of 1.5% per annum to 2030, which has been abandoned in its 2024 Sustainability Report. Qantas pilots have publicly stated that Qantas’ fuel efficiency claims were disingenuous, because Qantas’ push into ultra long-haul travel with ‘Project Sunrise’ will introduce 22-hour routes requiring carrying additional fuel and thus exceeding the most efficient flight length of 8-9 hours.
Qantas Course Correction: Toward Credible Net Zero Leadership
We believe Qantas can be a sustainability leader and we seek to support the company in its alignment with the climate science and Paris Agreement.
In order to restore public trust and establish its credibility as a leader in the transition to net zero, the company should undertake the following:
1. Establish Verified Credible Targets
Within 12 months, Qantas needs to verify its emissions reduction targets with the Science Based Targets Initiative (as other airlines have done). In particular, Qantas should set gross and intensity targets, rather than a ‘net’, emissions reduction target.
2. Develop a Credible Decarbonisation Pathway
Within 12 months, Qantas should align its decarbonisation strategies with the IEA industry pathway, including:
1. Acknowledging the critical role of demand management in aviation’s transition to net zero and include this solution in its Climate Transition Plan
2. Take a more realistic forecasting approach for the future scale up of alternative fuels
3. End “offsetting” of current fossil fuel emissions, where those emissions are outside Paris aligned decarbonisation trajectories. Set separate targets for emissions reductions and removals and only use removals to counterbalance truly residual emissions, as modelled in credible, Paris-aligned decarbonisation pathways such as the IEA.
3. Correct and End Greenwashing
Qantas should immediately correct misleading marketing and sustainability representations that may mislead consumers and investors, including its ‘fly carbon neutral’ and ‘green tier frequent flyer’ messaging
Want to dig into the detail? Download the full ACCC complaint.
References & Further Reading
Carbon Market Watch, ‘CORSIA: Hot air carbon credits cannot offset polluting planes’, (March 2024)
Client Earth & Fossielvrij, ‘Red Letter to Airlines’ (July 2024)
Climate Action 100+, ’Sector Strategy: Aviation - Recommended Investor Expectations’ (January 2021)
Climate Action 100+, ‘Qantas Profile’ (accessed 3 October 2024)
Climate Analytics, ‘Why offsets are not a viable alternative to cutting emissions’ (February 2023)
InfluenceMap, ‘Qantas Profile’ (accessed 3 October 2024)
Qantas Group, ‘Climate Action Plan’ (March 2022)
Qantas Group, ‘Sustainability Report 2024’ (September 2024)
Science Based Targets Initiative, ‘Aviation Guidance’ (accessed 3 October 2024)
Stay Grounded, ‘What is the climate impact of aviation?’, (accessed 16 September 2024)
Transition Pathway Initiative, ‘Qantas Profile’, (accessed 3 October 2024)
Images credits (with edits by Climate Integrity): Colin Lloyd, Joseph Bobadilla, Josh Withers, Nayla Charo, Sam Carter