Revised Green Guides help level the claims playing field

3 Min Read
Revised Green Guides help level the claims playing field



Author information: Anne Bedarf is a senior manager and Danielle Peacock is a project associate at GreenBlue's Sustainable Packaging Coalition. For additional information, please visit


After much anticipation, the Federal Trade Commission (FTC) released its revised Guides for the Use of Environmental Marketing Claims ("Green Guides") in October 2012. The new version contains important clarifications and additions to advance clear communication to consumers amidst the many complexities of environmental claims. 

New sections to the Green Guides include certifications and seals, carbon offsets, free-of claims, non-toxic claims, renewable energy claims and renewable material claims. These revisions accurately reflect today's packaging atmosphere and provide a helpful framework to communicate environmental attributes as we continue to see developments in renewables, non-toxics, material optimization and technology.

The FTC also addressed an important issue in the Green Guides by specifying that unqualified degradable claims may not be made for items destined for landfills, incinerators or recycling facilities. In addition, unqualified degradable claims are deemed deceptive "unless they can prove that the entire product or package will completely break down and return to nature within one year after customary disposal." This language disqualifies most, if not all, of the plastic degradable additive claims in the market today.

One of the most anticipated additions to the Green Guides is the clarification of recyclable claims. Many, including the Sustainable Packaging Coalition (SPC), have lobbied for the FTC to specify the percentage of the population that has access to recycling, which determines when an unqualified recyclable claim can be made. The FTC now has set the number for "substantial majority" at 60 percent. This is congruent with the "Widely Recycled" category of the SPC's How2Recycle Label, an on-package recyclability labeling system currently nearing the end of its soft launch. 

According to the Green Guides, items below 60 percent access must have qualifiers that "vary in strength depending on facility availability." The text contains some helpful examples, but the line is much less clear given that the FTC has removed "significant percentage" language. The How2Recycle Label addresses this by setting the cut-off for the "Check Locally" labels, which is considered a qualified claim, at 20 percent. Thus a product must have 20 percent or higher access to use that label. Packages between 20 and 60 percent access encourage action through the "Check Locally" language with the required qualifier of "not recycled in all communities." 

The Green Guides also address multiple components by cautioning against unqualified recyclable claims on items with components known to inhibit recycling. In addition, any item that is otherwise made from a recyclable material but treated, formed or sized in a way that prohibits recycling must also not receive a recyclable claim. 

Perhaps most importantly, the revisions state that "it is deceptive to misrepresent, directly or by implication, that a product, package, or service offers a general environmental benefit." This means that a broad claim like "eco-friendly" would be deceptive without qualifiers. Noticeably, no guidance is offered for the term "sustainable" though it is included in the Canadian version, which says, "At this time there are no definitive methods for measuring sustainability or confirming its accomplishment. Therefore, no claim of achieving sustainability shall be made."


While the revisions are helpful, "sustainable" is increasingly misused and the FTC missed an opportunity by not aligning this important facet of environmental marketing claims. We hope this will be included in the future.



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