The oil and gas industry’s peak lobby group, APPEA, has been referred to the Australian Competition and Consumer Commission (ACCC) for allegedly false or misleading statements regarding the relative greenhouse gas emissions of coal and gas. [1]

Lock the Gate and Comms Declare have asked the ACCC, through their lawyer, the Environmental Defenders Office, to investigate whether Australian Petroleum Producers and Exploration Association (APPEA) advertisements breach consumer laws [2] by understating the gas industry’s greenhouse gas emissions and exaggerating the importance of gas to the Australian economy and households.

The groups allege APPEA’s marketing statements falsely claim that:

  • The emissions intensity of gas is 50% that of coal. It is not. It is about 60% as polluting as coal and that’s before you count other lifecycle emissions.
  • Gas is replacing coal’s share of electricity generation in Australia. It is not. Renewable energy is largely replacing coal-fired electricity. 
  • Gas generates 20% of electricity used in Australia. It does not. Less than 6% of the National Electricity Market’s energy was generated by gas in the past financial year. 
  • APPEA is taking action consistent with achieving net zero emissions by 2050. It is not. Instead, APPEA is promoting the development of new gas projects, which is inconsistent with net zero by 2050.

APPEA makes other claims also alleged to be false including that: gas represented 27% of Australia’s household energy consumption in 2020-2021 and that the production of blue hydrogen releases low levels of carbon dioxide into the atmosphere. 

The letter of complaint [1] states the claims were part of a campaign by APPEA “to market fossil gas as a ‘clean’ energy source that is essential for the reduction of global greenhouse gas emissions to net zero by 2050 and to sustain the ‘Australian way of life’.”

The ACCC complaint follows a ruling by Ad Standards Australia on June 28 [3] that APPEA television ads in the same “family” of advertisements breached the Australian Association of National Advertisers’ (AANA) environmental codes. [4] It is only the fourth complaint ever upheld by AANA on environmental grounds since 2011.

Lock the Gate spokesperson Nic Clyde said: “We’re at a ‘fork in the road’ moment, where we need to back renewable energy to do the things gas used to.

“NSW is being urged to largely phase out gas by 2035. The Victorian and ACT governments already have well-developed plans to get off gas.

“Predictably, APPEA’s response is to double-down on their promotion of fossil gas: a fuel that is damaging our health, bad for our bank balances, and dangerous for our climate.

“The only thing we can trust the gas industry to do is promote its own interests above Australia’s.”

Comms Declare spokesperson Belinda Noble said: “We hope this is a turning point in preventing greenwashing by coal, oil, and gas companies.

“Gas is mainly methane, which heats the atmosphere 84 times more than carbon dioxide over 20 years.

“Advertising gas as being somehow ‘clean’ or ‘green’ is not only inaccurate — it is also immoral when global warming is causing record temperatures, death, and destruction around the globe.”

Comms Declare has released an ‘honest ad’ from APPEA to highlight the tactics and motivations behind the APPEA campaign.

EDO Managing Lawyer Kirsty Ruddock said: “Greenwashing is dangerous because it delays action on reducing greenhouse gas emissions and undermines competition and consumer trust in green or renewable products. 

“APPEA’s statements are designed to make the public think gas is good for the environment, when in fact it is driving dangerous climate change.

“It is clearly in the public interest to ensure big polluters and their peak bodies, such as APPEA, are held to account for their allegedly misleading or deceptive conduct.”


[1] ACCC complaint: Lock the Gate and Comms Declare v Australian Petroleum Producers and Exploration Association (APPEA). July 2023

[2] Lock the Gate and Comms Declare allege the APPEA marketing materials breached Australian Consumer Law (ACL) and the Competition and Consumer Act 2010 (Cth).

[3] 230628 – Ad Standards ruling 0119-23 – APPEA, June 28, 2023. APPEA disputed the findings but undertook to has modify or remove the ads in question.

[4] Australian Association of National Advertisers (AANA) Environmental Code 1—Truthful and Factual; AANA Environmental Code 2—Genuine Environmental Benefit; and AANA Environmental Code 3—Substantiation.


ACCC complaint: Lock the Gate and Comms Declare v Australian Petroleum Producers and Exploration Association (APPEA). July 2023


EDO | Managing Lawyer Kirsty Ruddock

Lock the Gate | Nic Clyde

Comms Declare | Belinda Noble


EDO | James Tremain | 0419 272 254 | [email protected]   


Lock the Gate: National grassroots organisation made up of over 120,000 supporters and 260 local groups who are concerned about the ongoing and rapid expansion of risky coal mining, coal seam gas and fracking. 

Comms Declare: Climate advocacy group consisting of more than 360 marketing, PR, advertising and media organisations who have committed not to support activities or organisations that promote the growth of fossil fuels, high greenhouse gas pollution or deception around climate science.

Environmental Defenders Office (EDO): Largest environmental legal centre in the Australia-Pacific, dedicated to protecting our climate, communities and shared environment by providing access to justice, running ground-breaking litigation and leading law reform advocacy.