As part of Walmart's commitment to sustainability, the Walmart packaging team has hosted an annual Sustainable Packaging Expo in Rogers, AR, since 2006. The expo is a not-for-profit event that enables Walmart product vendors and packaging suppliers to learn about new techniques and technologies to reduce their packaging while meeting customer needs.
Beginning with the event's fourth year, Walmart introduced an audit protocol to help educate packaging suppliers on the proper use of environmental claims. Under this protocol, all exhibitors must provide their expo booth marketing materials (limited to a two-page standardized handout) to a third party, Environmental Packaging Intl. (EPI). The company reviews them for conformance with U.S. Federal Trade Commission (FTC) guidelines, as well as stricter Walmart requirements. Prior to submission, exhibitors are provided an educational document developed by Walmart and EPI that explains appropriate claims use.
The FTC "Green Guides," first issued in 1992, with revisions proposed in 2010, prohibit companies from making misleading claims about the environmental attributes of a product or package in labeling, advertising, promotional materials or other marketing.
They are intended to protect the consumer (including businesses) from being deceived or misled. Specifically, they require that companies:
• Tell the truth;
• Not overstate a product's attributes;
• Use prominent qualifications;
• Have reliable evidence to back up claims.
Each year, close to 200 Walmart Expo exhibitors submit their materials to EPI for review. The results have steadily improved since the launch of the reviews in 2009 (in all but one year, when Walmart introduced a new requirement), thanks to a better understanding of FTC criteria among participants, as well as feedback on previous years' handouts.
In 2009, EPI recorded a 70 percent rejection rate for the first submission of the marketing handout. Half of participants still did not receive approval after their third submission of the handout.Even if an exhibitor's material does not pass EPI's initial audit, with the help of the audit team, all companies are eventually approved for attendance at the expo, typically in three to four attempts.
However, in 2012 EPI's rejection rate for the first submission of the handout decreased to 40 percent. All of the participant handouts were approved by their third submission.
While approval rates continue to climb, the submissions reveal that many companies still struggle with certain claims, most notably:
• Environmental Benefit. Companies are not allowed to include claims that their product or package offers a general environmental benefit, such as "environmentally friendly," "green" or "the most sustainable material." Unless these statements can be substantiated and qualified, they will fail the expo review.
• Recyclability. If the entire product or package is accepted by a substantial majority of recycling programs, expo participants may use an unqualified recyclability claim. Otherwise, qualifying text must be included, even if an item is technically recyclable. For example, one previous expo handout statement that said, "Package is made of monolayer PP and it can be recycled in the United States," could only be made with qualification.
• Compostable. Compostable claims can only be made if all the materials will become part of usable compost and must qualify whether the materials are compostable in home, municipal or industrial composting facilities. If the material is only suitable for municipal or industrial facilities, claims must include text about their limited availability.
• Source reduction and carbon offset. Companies cannot include claims about their reduced weight, waste, toxicity or greenhouse gas emissions unless they include the basis for the comparison, appropriate methodologies and reliable scientific evidence.
• Biodegradable. Since most biodegradable packaging ends up in landfills where the conditions for biodegradation are not met, any such claims must be qualified to avoid consumer deception about the packaging's ability to degrade where it is typically disposed. After recognizing the challenges in qualifying the claim, companies now are less apt to include biodegradable claims. In 2012, only two expo submissions attempted to include a biodegradable claim in their handouts.
Details earn approval
Over the past four years, EPI found progressively fewer unqualified claims in the expo handouts. Submissions have included more supporting details about the packaging attributes, based on a variety of environmental analysis.
To maximize the chance of approval of a first submission, all future Walmart Expo participants should follow these guidelines:
• Make any qualifying language prominent and understandable;
• Be specific about packaging environmental attributes and properties;
• Always have substantiation for "compostable" claims;
• Clearly state the recyclability access for products or packages that are accepted in less than a substantial majority of recycling programs;
• Avoid "biodegradable" claims;
• For quantitative environmental claims such as CO2 or carbon footprint reduction, indicate what factors have been reduced, to what level and what tool was used to estimate the reduction.
The FTC guidelines were developed to help avoid greenwashing. The Walmart Expo has become a valuable venue for educating suppliers on their requirements and ensuring customers know what they're buying-and why.
Sha Sha is senior project manager at Environmental Packaging Intl., a consultancy specializing in packaging sustainability and compliance with global product stewardship laws. For more information, visit www.enviro-pac.com or call 401-423-2225.