T&E response to the public consultation on the Flight Emissions Label

While Transport & Environment welcomes the Label as an opportunity to provide greater transparency in aviation emissions, the proposed Implementing Act has several issues:

• The non-CO₂ effects of aviation are yet again hidden from passengers.

• The proposed method to apportion emissions to belly cargo would hide an additional 4 Mt of CO₂ from European consumers, equal to 4% of all passenger emissions.

• CO₂ efficiency per kilometre is not a relevant indicator to assess the environmental impact of a flight.

• Comparing the emissions of a given flight only to emissions of other flights on the same route is misleading whenever a train alternative is available.

• Passengers should be given more information about SAF than its life cycle emissions.