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FTC Revised Green Guides Get Tough On Products, Packaging, Not Food

On October 1, 2012 the Federal Trade Commission issued the long awaited revised “Green Guides” guidelines that are designed to help marketers ensure that the claims they make about the environmental attributes of their products are truthful and non-deceptive. The Green Guides, first issued in 1992 have been long criticized for not having enough teeth. These new revisions have been well received with green Marketing Guru Jacquelyn Ottman, in her blog post assessing the revised FTC Green Guides, ging so far as to say that the FTC has finally “nailed it”:

… In their infinite wisdom, the FTC is finally putting their foot down about “planets, babies and daisies” and terms such as “environmentally friendly”. Their Enforcement Division is ready to pounce … The revisions to the Green Guides show that the FTC is putting their foot down (both of them) about such generalized environmental claims as ‘green’, along with such related terms as ‘eco-friendly’ and ‘environmentally friendly’.

She goes on to say:

While they are at it, they’re advising against the use of any label, logo, seal or product name or image … that can imply any hint of environmental (or health) superiority without adequate scientific support.

Although there are several tweaks to the previous revisions of the Green Guide, the most significant of the final revisions seems to be the FTC’s position on “general environmental benefits”– claims that a product is “eco friendly” or “green.” The FTC is requiring proof of any stated environmental benefit:

Because it is highly unlikely that marketers can substantiate all reasonable interpretations of these claims, marketers should not make unqualified general environmental benefit claims.

This could have had real implications for labels on foods, an industry plagued with labels, logos and seals that imply environmental or health superiority (like Frito-Lays and POM and Skinny Girl Cocktails to name a few). Although, sadly, widely overused food labels such as “natural” and “sustainable” are not addressed so I’m not sure how much food labeling will actually improve. It seems that many household products could be impacted, but why not food products? The FTC’s explantion:

Finally, either because the FTC lacks a sufficient basis to provide meaningful guidance or wants to avoid proposing guidance that duplicates or contradicts rules or guidance of other agencies, the Guides do not address use of the terms “sustainable,” “natural,” and “organic.”  Organic claims made for textiles and other products derived from agricultural products are covered by the U.S. Department of Agriculture’s National Organic Program.

The areas addressed in the Green Guides are:

  • General Environmental Benefit Claims.
  • Carbon Offsets.
  • Certifications and Seals of Approval.
  • Compostable Claims.
  • Degradable Claims.
  • Free-Of Claims.
  • Non-Toxic Claims.
  • Ozone-Safe and Ozone-Friendly Claims.
  • Recyclable Claims.
  • Recycled Content Claims.
  • Refillable Claims.
  • Renewable Energy Claims.
  • Renewable Materials Claims.
  • Source Reduction Claims.

Ottman’s excellent blog post points out many important issues about green marketing claims and greenwash.  Some of my favorite include:

  • There’s no such thing as a totally green product.
  • One attribute does not a green product make.
  • 100% recycled content can be less ‘green’ than 10% recycled content.
  • Sustainable is a moving target.

As I’ve said many times before on this blog, we consumers, have a lot of power to convince packaged goods companies to do better.  Ottman suggests:

We in industry — and concerned consumers, too — should get on the case of questionable green claims. In their infinite wisdom and thoroughness, the FTC provides lots of helpful information for marketers and to the public to make the process of reporting such claims easy.  (The National Advertising Division of the Better Business Bureau can help a lot, too.)

Finally, to address the issue that many ecopreneurs confront, ‘if we do our jobs right we’ll put ourselves out of business,’ Ottman has this to say:

… let’s agree to put ourselves out of the ‘save the planet’ business and into the business of saving our customers some money, time, etc. in an environmentally sound way — and make our marketing more legitimately green for our bottom lines …

You can read a full analysis in Ottman’s blog post, Upshot of FTC Revised Green Guides: Stop Touting Products as “Green.” And, for more sage wisdom on green marketing and how to avoid greenwash you can subscribe to Jacquie Ottman’s Green Marketing Blog.

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