Client environmental claims guide

1. The short rule

Say exactly what the evidence proves, at the level and for the beneficiary shown on the retirement record. Do not turn a purchase, allocation or contribution into a claim that physical SAF was delivered to your aircraft, that a particular flight used SAF, or that your organisation is carbon neutral. If a statement cannot be traced to the certificate, methodology and retirement evidence, do not publish it.

2. Claim status

• Before verified retirement: you may describe a commitment, purchase or support for a project, but not a completed emissions benefit.
• After verified retirement: you may describe the quantity of SAF environmental attributes allocated and retired for the named beneficiary through a book-and-claim chain.
• Quantified CO2e: use only the figure, unit, baseline, lifecycle boundary and methodology stated in the final evidence pack; do not independently convert tonnes of SAF into tonnes of CO2e.
• Prototype orders: no external claim is permitted. All current products, figures, facilities, retirements and certificates are synthetic.

3. Safer example wording

“[Beneficiary] purchased and retired SAF environmental attributes representing [quantity] tCO2e, as quantified in the verified evidence pack through a book-and-claim system. The SAF was not physically delivered to our aircraft. The associated lifecycle emissions information, methodology, system boundary and retirement evidence are set out in our evidence pack.” Adapt this wording only where every inserted fact is supported by final evidence.

4. Claims requiring separate substantiation and approval

• “We flew on SAF”, “our flight was powered by SAF” or any physical-delivery statement
• “Carbon neutral”, “climate neutral”, “net zero”, “zero emissions”, “carbon positive” or “offset”
• A claim that the purchase reduced the emissions of a particular flight, product, service or the whole organisation
• A percentage-reduction claim that omits its baseline, scope, lifecycle boundary, period or methodology
• A Scope 1, Scope 3, target-progress, regulatory-compliance or accounting claim not expressly supported by the applicable reporting standard
• Any environmental label, badge or comparative claim implying independent certification or superiority

5. Information that must travel with a claim

• The words “book-and-claim” and a clear statement that physical custody or delivery is not implied
• Beneficiary, quantity, unit, vintage, project or pathway and relevant geography
• Lifecycle methodology, baseline, system boundary, exclusions and material uncertainty
• Registry or ledger, unique retirement reference and retirement date
• Verification status and the identity and scope of any independent assurance
• A link to the current evidence and disclosure page wherever the format permits

6. Client approval workflow

• Keep a claim register containing the exact wording, audience, channel, owner and publication date.
• Attach the certificate, retirement record, calculation, methodology and current disclosure to each claim.
• Obtain sustainability and legal approval before publication, and renewed approval after any wording or evidence change.
• Preserve the approved version and supporting evidence for at least the period required by applicable law and your reporting framework.
• Correct or remove a claim promptly if evidence is revised, reversed, disputed or FEG requests a correction.

7. Double counting and ownership

A completed-benefit claim may be made only after the relevant attribute is uniquely allocated and retired for the named beneficiary and the evidence shows it has not been sold, transferred or claimed elsewhere. Clients must not resell, split, transfer or permit another party to claim the same retired attribute unless the governing programme expressly allows it and the evidence is updated.

8. Regulatory overlays

Claims must be adapted to the audience and jurisdiction. Consumer, investor, annual-report, sustainability-report, aviation and target-accounting statements can be governed by different rules. In particular, EU consumer-facing product claims based on greenhouse-gas offsetting require special caution; UK claims should follow the Green Claims Code principles; and US claims should follow the FTC Green Guides and applicable state disclosure rules, including California AB 1305 where relevant.

9. Allocation of responsibility

FEG is responsible for the accuracy of information it supplies and for performing the services it expressly agrees to provide. The client is independently responsible for selecting, adapting, approving and publishing its own statements, reports, advertisements and disclosures, and for complying with the laws and reporting standards applicable to them. FEG materials are supporting evidence, not legal, accounting, assurance or sustainability-reporting advice.

The client must not remove qualifications, alter evidence or imply that FEG approved wording it did not approve. To the maximum extent permitted by law, the client is responsible for loss, regulatory action or third-party claims caused by its unsupported, altered or misleading downstream claims. Any production indemnity and limitation of liability must be set out in signed terms and reviewed by qualified counsel; nothing excludes responsibility that cannot lawfully be excluded or liability arising from FEG’s own fraud, wilful misconduct, negligence or misrepresentation.

10. Prototype notice

This guide is a prototype control framework populated with illustrative content. It is not legal advice and does not itself make any product, project or claim compliant. Qualified counsel should approve the production wording, evidence standard, contracting terms and jurisdiction-specific workflow before launch.