Summary
Details
- Global
Mandatory: Supplier Code compliance and applicable legal requirements.
Functionally mandatory: environmental data and compliance documentation for relevant suppliers.
Explicitly stronger requirements: fuel, aircraft, maintenance, ground handling and other high-impact suppliers.
Regulatory mandatory: SAF, emissions trading and climate compliance obligations where applicable.
Market-dependent: customer SAF contributions and voluntary climate products.
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What’s Required
Lufthansa Group has developed an aviation value chain governance system focused on reducing the climate impact of flight operations while managing supplier and partner performance across a complex airline group. Unlike manufacturing companies, Lufthansa’s emissions profile is dominated by aircraft fuel combustion, but its climate governance extends across fuel suppliers, aircraft manufacturers, maintenance providers, airports, ground handlers, catering suppliers, logistics partners and corporate procurement.
The architecture includes:
Supplier Code of Conduct.
Lufthansa Group Code of Conduct.
Climate and environmental strategy.
Science-based Targets initiative validation.
SAF procurement and customer contribution programmes.
Fleet modernisation and operational efficiency measures.
Environmental management systems at airline and airport operations.
Scope 1, 2 and 3 reporting.
EU and international aviation regulation compliance.
This creates a fuel- and operations-based aviation governance model, where supplier performance, fuel availability, aircraft efficiency and customer demand all affect the group’s decarbonization pathway.
Lufthansa Group states that it aims to halve net CO₂ emissions from flight operations by 2030 compared with 2019 through reduction and compensation measures, and to achieve a neutral CO₂ balance by 2050. Its 2030 reduction target was validated by the Science Based Targets initiative in August 2022.
1. Emissions Disclosure, Measurement and Reduction
Lufthansa Group measures and reports emissions across:
Aircraft operations.
Ground operations.
Fuel supply chains.
Purchased goods and services.
Maintenance and repair activities.
Logistics and catering.
Airport and office energy use.
Upstream fuel production and transport.
Suppliers and partners are required or expected to:
Comply with environmental and climate protection requirements.
Avoid serious environmental damage.
Reduce emissions from services and materials.
Provide data where required.
Support energy efficiency and resource efficiency.
Align with Lufthansa’s environmental expectations.
For strategic suppliers, this may include:
Emissions and fuel-related data.
SAF lifecycle documentation.
Environmental performance information.
Participation in monitoring or supplier assessments.
Support for operational decarbonization measures.
The Lufthansa Group Supplier Code of Conduct states that suppliers should not cause serious environmental damage and should not pollute air or water, release harmful noise emissions or consume excessive water; it also states that Lufthansa Group reserves the right to stipulate specific environmental and climate protection requirements and regularly monitor compliance.
This establishes a supplier-linked aviation emissions disclosure model, where direct flight emissions remain central, but upstream supplier performance increasingly affects climate reporting and procurement decisions.
2. Scope 3 Governance and Value Chain Integration
Lufthansa Group’s Scope 3 exposure is shaped by:
Upstream jet fuel production and transport.
Aircraft and engine manufacturing.
Purchased goods and services.
Capital goods.
Maintenance, repair and overhaul supply chains.
Catering and onboard products.
Ground handling and airport services.
Passenger and cargo logistics connections.
Employee travel and commuting.
Suppliers must:
Provide environmental data where relevant
Comply with procurement and supplier standards
Support efficiency, fuel transition and emissions reduction
Align with Lufthansa’s sustainability expectations
This creates an aviation Scope 3 governance model, where emissions are managed through both:
Operational control over flights and ground operations
Value chain influence over fuel, aircraft, suppliers and customer-facing climate products
Lufthansa’s validated SBTi target for aircraft operations covers Scope 1 as well as Scope 3 Category 3, meaning upstream fuel and energy-related emissions are explicitly incorporated into its climate target structure.
3. Supplier Code and ESG Data Architecture
A defining feature is Lufthansa’s use of supplier conduct rules and group-wide environmental governance.
Suppliers must:
Comply with applicable laws and regulations.
Respect environmental standards.
Avoid serious environmental harm.
Meet specific environmental and climate protection requirements where stipulated.
Permit monitoring of compliance where required.
Cascade standards to relevant business partners where applicable.
The supplier system supports:
Supplier risk management.
Contractual sustainability expectations.
Environmental monitoring.
Compliance escalation.
Procurement qualification.
Alignment with German and European supply chain due diligence expectations.
This creates a contractual supplier governance architecture, where climate and environmental requirements can be specified and monitored by procurement.
The Lufthansa Group Code of Conduct also serves as an orientation aid for business partners, communicating the expectation that they comply with all applicable laws.
4. Sustainable Aviation Fuel and Fuel Supply Chain Governance
SAF is a central decarbonization lever for Lufthansa Group.
The framework affects:
Fuel suppliers.
Refiners and SAF producers.
Bunkering providers.
Airports.
Corporate customers.
Passenger climate products.
Regulatory compliance under EU SAF mandates.
Suppliers and partners are expected to support:
SAF availability
Fuel lifecycle emissions documentation
Sustainable feedstock criteria
Fuel certification
Reliable supply contracts
Transparent emissions accounting
This creates a marine-style fuel transition governance layer for aviation, where emissions reduction depends on verified fuel attributes rather than only operational efficiency.
Lufthansa Group reported that SAF use reduced 71,952 tonnes of CO₂ in 2024, including 63,943 tonnes from direct combustion savings and 8,009 tonnes from upstream production and transport savings compared with fossil kerosene. The same disclosure reported SAF at 0.2% of fuel use.
5. Fleet Modernisation and Aircraft Lifecycle Governance
Lufthansa Group’s climate strategy depends heavily on fleet renewal.
Supplier implications include:
Aircraft manufacturers must deliver more efficient aircraft.
Engine suppliers must improve fuel efficiency and reliability.
Cabin and materials suppliers must support lightweighting.
Maintenance providers must optimise performance.
Leasing and finance partners must support capital transition.
This creates an aircraft lifecycle governance layer, where product efficiency determines emissions over decades of operation.
The framework directly affects:
Fuel burn per seat kilometre.
Aircraft noise.
Maintenance-related emissions.
Capital expenditure decisions.
Route economics.
Passenger carbon intensity.
Fleet modernization is therefore both a decarbonization lever and a supplier governance mechanism, because procurement choices shape long-term emissions exposure.
6. Airport, Ground Operations and Renewable Electricity
Lufthansa Group’s environmental governance also covers ground operations.
Suppliers and partners may be expected to support:
Renewable electricity procurement.
Electric ground support equipment.
Low-emission airport services.
Efficient building operations.
Waste reduction.
Water and resource management.
Lower-emission maintenance and logistics.
Lufthansa Group has set a target for ground operations in Germany, Austria and Switzerland to source electricity exclusively from renewable energies.
This creates a ground operations decarbonization layer, where airport infrastructure, maintenance facilities and service partners affect Scope 2 and Scope 3 performance.
7. Audit, Verification and Monitoring Systems
Lufthansa Group enforces compliance through:
Supplier Code requirements.
Contractual clauses.
Procurement checks.
Environmental management systems.
Data verification for emissions reporting.
Monitoring of supplier compliance where stipulated.
Corrective action processes.
Regulatory reporting under aviation and EU climate rules.
Suppliers must:
Provide documentation.
Comply with environmental requirements.
Support monitoring where required.
Address non-conformances.
Maintain environmental and compliance systems.
This creates a hybrid verification model, combining supplier compliance, environmental management, regulatory reporting and fuel-related verification.
Lufthansa’s environmental statements describe environmental management structures within Lufthansa Airlines, including dedicated responsibilities for SAF, efficiency measures and communication.
8. Procurement Integration and Supplier Segmentation
Environmental performance is embedded into procurement through:
Supplier onboarding.
Supplier Code acceptance.
Contractual environmental requirements.
Fuel procurement decisions.
Aircraft procurement decisions.
Service-provider qualification.
Sustainability criteria in corporate purchasing.
Suppliers are segmented based on:
Strategic importance.
Emissions relevance.
Fuel and energy exposure.
Aircraft lifecycle impact.
Operational risk.
Regulatory exposure.
Country and due diligence risk.
High-impact suppliers face:
Stronger environmental requirements.
Greater data expectations.
More monitoring.
Potential climate-linked procurement criteria.
Higher pressure to support Lufthansa’s SAF and efficiency pathway.
This results in a risk- and emissions-differentiated supplier governance model.
9. Upstream Cascade Requirements
Suppliers are expected to:
Comply with Lufthansa’s standards.
Manage environmental risks in their own operations.
Avoid serious environmental harm.
Support transparency across relevant supply chains.
Ensure subcontractors and business partners meet applicable requirements.
This extends governance into:
Fuel production and refining.
SAF feedstock supply chains.
Aircraft and engine manufacturing.
Maintenance and repair networks.
Catering and onboard retail suppliers.
Ground handling contractors.
Airport service providers.
IT and corporate service suppliers.
The framework therefore operates across deep aviation value chains, from fuel molecules to customer-facing travel products.
10. Lifecycle and Service-Level Implications
The framework directly affects:
Flight emissions.
Passenger carbon intensity.
Cargo transport emissions.
Fuel supply chain emissions.
Aircraft lifecycle performance.
Ground operation emissions.
Customer-facing climate products.
Aviation regulatory cost exposure.
Supplier performance influences:
Scope 1 and Scope 3 reporting.
SAF availability and credibility.
Fleet emissions trajectory.
Passenger and corporate customer disclosures.
EU ETS and ReFuelEU Aviation cost management.
Corporate travel Scope 3 claims.
This makes Lufthansa Group a strong example of aviation service-level Scope 3 governance, where the carbon intensity of travel services is shaped by fuel procurement, aircraft procurement, supplier performance and regulatory compliance.
Important Deadlines
Key timelines include:
2030 target to halve net CO₂ emissions from flight operations compared with 2019.
2050 target to achieve a neutral CO₂ balance.
Annual sustainability and non-financial reporting cycles.
Ongoing SAF procurement and regulatory compliance cycles.
EU SAF mandate escalation through 2030 and beyond.
Supplier monitoring and compliance requirements where stipulated.
Lufthansa Group’s 2024 reporting confirms climate targets and states that its validated SBTi target covers Scope 1 and Scope 3 Category 3 from aircraft operations.
Current Status
The framework is active and expanding.
Current focus areas include:
SAF procurement and customer climate products.
Fleet modernization.
Operational efficiency.
Renewable electricity for ground operations.
Supplier environmental requirements.
EU regulatory cost management.
Scope 1 and Scope 3 fuel-related emissions accounting.
Lufthansa Group reported 2024 SAF-related savings but also disclosed that SAF represented only 0.2% of relevant fuel use, showing that the transition is active but still at an early scale.
The group has also introduced regulatory and SAF-related cost pass-through measures. The Financial Times reported that Lufthansa planned a green surcharge from 2025 to cover rising costs from SAF and environmental regulations on flights departing from EU countries, the UK, Switzerland and Norway.
Penalties for Non-Compliance
Enforcement may include:
Corrective action requirements.
Supplier monitoring escalation.
Loss of preferred supplier status.
Reduced procurement opportunities.
Exclusion from contracts.
Contract termination.
Regulatory cost exposure.
Commercial disadvantage in corporate travel procurement.
This creates a direct link between supplier environmental performance and aviation market access.
Examples of Known Failure Modes
Typical risks include:
Insufficient SAF availability.
Incomplete lifecycle emissions documentation.
High SAF cost and limited supply.
Weak supplier environmental data.
High aircraft fuel intensity from older fleets.
Airport infrastructure constraints.
Ground service emissions gaps.
Catering and waste management inefficiencies.
Regulatory cost pass-through disputes.
Customer scepticism over climate claims.
These failures affect emissions reduction, compliance costs, customer trust and procurement eligibility.
Industry-wide SAF constraints remain material. Reuters reported in 2025 that European airline leaders, including Lufthansa, warned that SAF targets risk being missed because of high costs and limited availability.
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