FTC workshop re-examines 'Green Guides'

Much of the Federal Trade Commission (FTC) Green Guide workshop in April was spent on topics like the prevalence of unsubstantiated and vague claims of general environmental benefit, such as “earth friendly.” However, there were several new terms and issues raised that reflect the desire to communicate in an increasingly environmentally conscientious and global marketplace. Some of these topics include the growing complexity of environmental evaluation and use of terms like “sustainable,” “renewable” and “compostable.”

The Green Guides, formally known as “Guides for the Use of Environmental Marketing Claims,” refer to an FTC oversight of environmental advertising and marketing practices. An important restriction of the FTC's role noted that day, is that the FTC isn't authorized to develop standards or definitions. And while the FTC does have enforcement authority, it was pointed out that it is seldom exercised. There was general applause over a suggestion that one course of action might include greater enforcement of compliance with the Green Guides. The sentiment of workshop attendees was that awareness of the Green Guides is generally low and an effort to educate the industry on their use is sorely needed. Participants kept highlighting the need for more specific guidance, clearer definitions and standards supported by transparent methodologies. This feedback highlights a wide gap in the FTC's role as the center of guidance without the authorization to develop needed standards, and leads to a necessary question as to whose role it is to develop these standards.

A review of the Green Guides every five years was recommended, but suggestions that an ongoing process could identify and flag new issues more often emerged as an important recommendation.

The proliferation of carbon-related claims over the past years is a timely example of the desire to address new environmental issues as they come up and the concurrent need to keep the Green Guides relevant.

Another discussion focused on the growing use of life-cycle analysis and the growing complexity of marketing claims through terms like “sustainability.” It was pointed out that there is inherent contradiction in trying to summarize systems information through claims like “renewability,” “energy efficiency” and “recycled content.” A clarification made toward the end of the meeting indicated that the Green Guides apply not only to retail consumers, but also to business consumers in business-to-business interactions. For instance, a retailer requesting environmental information from a supplier should expect the same kind of substantiation to support environmental claims as an end consumer.

Companies should be recognized and rewarded for legitimate and substantiated efforts to address and improve their environmental performance—packaging is no exception. There's an opportunity to come together and figure out definitions, standards and methodologies for the environmental claims most meaningful for packaging. A webcast and transcripts of the session are available at http://www.ftc.gov/bcp/workshops/packaging/index.shtml.