If you’re a marketer of “green,” “eco-friendly,” “natural,” “sustainable,” or “organic” products, today’s date – December 10, 2010 – should be circled on your calendar.
It’s the last day to voice your opinion about the first change to the Federal Trade Commission’s “Green Guides” since 1998. The Green Guides help marketers to avoid making misleading environmental claims (and thus being subject to pesky, expensive, and brand damaging law suits and FTC enforcement actions). The “Green Guides” include new guidance on marketers’ use of product certifications and seals of approval, “renewable energy” claims, “renewable materials” claims, and “carbon offset” claims.
You can file your comments on the proposals electronically – just be aware they will be part of the public record.
There’s been a lot of online chatter about the upcoming revisions since well before their release in October.
Here are a few of my favorite blog posts about the impending changes, and how they may impact sustainability communications and green marketing:
- An Open Letter to the FTC: Shelton Group
- FTC Ending Green Marketing’s Wild West? Top 4 Things to Know: SDialogue
- Green Guide Revisions: How Will They Affect You: Packaging World
- FTC’s Updated Green Claim Regs: Bull’s Eye In Letter And Spirit: Marketing Green, MJ Jolda
- FTC’s New Green Marketing Guidelines Go After Greenwashers: Natural Home Living
- FTC Green Guides: The End of Eco-Friendly? Plant Friendly? Earth Friendly?: The Smart Mama
- What The FTC’s Green Guides Mean For The Market: Ecopreneurist, Thomas P. Leon
Unfortunately, not all marketers are paying heed. In September, I reviewed some marketing materials for a renewable energy company – and pointed out that rather than promote their products as “eco-friendly,” a stronger claim would be “energy efficient.”
And in fact, when the proposed revised Guides were released in October, they cautioned marketers not to make blanket, general claims that a product is “environmentally friendly” or “eco-friendly.” The FTC’s consumer perception study confirmed that such claims are likely to suggest that the product has specific and far-reaching environmental benefits. While one could argue that a solar powered device does have far reaching environmental benefits, why choose to describe them with the word “eco friendly,” which is often associated with greenwashing?
Here’s a copy of my comments, as submitted to the FTC this afternoon. What do you think? Did you share your thoughts with the FTC? We’ll all be abiding by these rules in the years to come, and now’s your only chance to make your voice heard!
To the Commission:
As a consumer of “green products,” an environmental activist, and an advisor to companies marketing products and services impacted by your guidance, I offer my thoughts on your proposed guidelines.
1. I suspect that your proposal to restrict the use of the terms “eco friendly” and “environmentally friendly,” while simultaneously deciding to avoid passing judgment on terms such as “sustainable,” “natural,” and “organic” may have the unintended consequence of leading all marketers who previously used the former terms to simply substitute the latter terms.
2. Since the terms “eco friendly” and “environmentally friendly” are in such common use, restricting those terms will require marketers to revise large quantities of marketing materials (in and of itself a practice that is not environmentally friendly!). Any guidance you issue here should be extremely explicit – with examples –to minimize any confusion in the marketplace.
3. The issue of private certifications is one of the most confusing parts of the green marketing landscape. I used to think it was just consumers who were confused, but when I attended a professional meeting run by the Soap and Detergent Association, I learned that manufacturers are just as confused as consumers. There are 100s of these “certifications” – even thousands worldwide – with no set standard of measurement. How are private certifications regulated? Which are meaningful? Which are not? Since label reading is the primary means by which consumers determine the legitimacy of a claim, it is critical that any label on a product stand for something credible.
4. I believe you need to strengthen the regulation of the term organic. Under the USDA Organic NOP standards, companies must pass very stringent tests in order to carry the USDA Organic seal. Yet in other sectors, any producer can call a product “organic” with minimal organic content. This is extremely confusing to consumers, as well as unfair to legitimate organic producers.
5. Your decision to defer judgment on Life Cycle Analysis should not be put off indefinitely. LCA has the potential to revolutionize standard measurement of a product’s environmental impact, thus helping consumers and manufacturers to make better decisions. Please consider issuing a statement regarding your plans to address LCA more completely.
Thank you for your consideration.
What do you think? Leave a comment and share!
Copyright 4GreenPs 2010