Sources: Federal Trade Commission (FTC); CP staff
Through its revised “Green Guides,” FTC aims to help marketers ensure that claims about their products’ environmental attributes are truthful and nondeceptive. Revisions reflect hundreds of industry and consumer comments on previously proposed revisions, plus new sections on carbon offset references, “green” certifications and seals, and renewable materials claims.
Specific to carbon offsets, FTC officials note that marketers a) should have competent and reliable scientific evidence to support claims and use appropriate accounting methods to ensure they measure emission reductions properly and one time only; and, b) should not advertise an offset if the law already requires the activity that is the basis of such credit.
The agency recommends that marketers qualify specific environmental benefit claims instead of making broad, unqualified “green” or “eco-friendly” claims. Qualifications should be clear, prominent, and specific. If a qualified general claim conveys that a product has an overall environmental benefit because of a specific attribute, marketers should analyze the trade-offs resulting from the attribute to prove the claim.
Green Guides directs marketers to disclose any material connections to organizations providing product certifications or seal of approvals, and avoid claims that don’t convey the basis for certification. Claiming “Green, made with recycled content” may be deceptive if the environmental costs of using recycled content outweigh the environmental benefits of using it.
The FTC first issued its Green Guides in 1992, revising them in 1996, 1998 and 2010. They provide general principles that apply to all environmental marketing claims; perspective on how consumers are likely to interpret particular claims; and, suggestions on how marketers can qualify their claims to avoid deceiving consumers. The October 2012 Green Guides version can be downloaded by clicking here.