| Comment Number: | 533431-00001 |
| Received: | 1/7/2008 4:24:14 PM |
| Organization: | ARC, a Formglas company |
| Commenter: | Brian McDonald |
| State: | PA |
| Agency: | Federal Trade Commission |
| Rule: | Guides for the Use of Environmental Marketing Claims |
| Attachments: | 533431-00001.pdf Download Adobe Reader |
Comments:
Our organization operates companies in the USA and Canada. This comment requests a modification to the “Recycled Content “ claim clause, 260.7 (e), of Part 260 – Guides For the use of Environmental Marketing Claims. The wording of clause 260.7 (e) limits recycled content materials to only those diverted from the “solid” waste stream. This clause advocates poor environmental policy and creates situations of unfair competition amongst different product systems. Details to follow explain a fundamental flaw and environmental shortsightedness with this clause that will become obvious. However in addition, I have attached a Ruling by the ISO (International Organization for Standardization) Technical Committee for ISO Standard 14021 - Environmental Labels and Declarations – Self-declared Environmental Claims which validate these comments. It should be noted that the Secretariat of ISO/TC 207, the technical committee for environmental management, is held by the Standards Council of Canada (SCC) and administered by Canadian Standards Association (CSA). The ISO 14021 standard has the same purpose as the aforementioned FTC guide and has been adopted by most industrialized nations on the planet, including the USA. It does however have a different policy with respect this specific matter concerning “Recycled Content” definitions. Immediately below is the text of the subject clause (cut and pasted) from the FTC website: Part 260 -- GUIDES FOR THE USE OF ENVIRONMENTAL MARKETING CLAIMS 260.7 (e) Recycled content: A recycled content claim may be made only for materials that have been recovered or otherwise diverted from the solid waste stream, either during the manufacturing process (pre-consumer), or after consumer use (post-consumer). The problem with this clause is that it limits recycled content materials to only those materials “recovered or otherwise diverted from the solid waste stream”. This unfortunately means that many “non-solid” waste materials such as petroleum products, paints, resins, and water which should be recycled do NOT qualify as recycled content material by this FTC definition. Many of these “non-solid” waste materials represent a much greater environmental hazard with respect to their disposal than do “solid” waste materials. This is particularly problematic because these liquid waste materials are so easily disposed of down drains ( out of sight of others and with no cost for disposal ) and those wastes most often lead to our lakes and streams and therefore indirectly to sources of municipal water. The current FTC policy limiting recycled content materials to only those diverted from the “solid” waste stream therefore discourages industry and other commercial enterprises from investing in processes and commercial ventures to “recycle” liquid waste materials. In addition, manufacturers of products that include non-solid material inputs are disadvantaged by this FTC policy because they can NOT possibly have as high a “qualifying” recycled content as products with only solid material inputs. Unfortunately, many consumers identify the percentage of recycled content as a measure of the environmental merits of a product, consequently, consumers may be misled into making purchase decisions believing a product made with only solid materials and a higher “qualifying” recycled content than a product which uses “non-solid” recycled content, which may well offer more environmental benefits. A high degree of importance should be placed on this matter since water is becoming more scarce, particularly in the US Southwest. In fact, water resources are an important political campaigning policy in these areas and it should be self evident that industry should be “encouraged” and NOT “discouraged” from trying to reduce their use of potable water for manufacturing processes. Recommendation: Modify the wording of clause 260.7 (e) so that it does NOT limit Recycled Content to solid waste materials. Thank You