|Received:||1/7/2008 5:13:25 PM|
|Organization:||EnviroMedia Social Marketing Inc.|
|Agency:||Federal Trade Commission|
|Rule:||Guides for the Use of Environmental Marketing Claims|
Comments:Full Disclosure Should Be Required for Carbon Offsets by Kevin Tuerff, President and Principal EnviroMedia Social Marketing January 7, 2008 With so much focus on global climate change, many companies, nonprofit organizations, and consumers are rushing to “do something” to demonstrate their environmental commitment. Perhaps the fastest growing example is the sale and purchase of carbon offsets. This environmental “sin tax” or “indulgence” allows the buyer to donate money to a company or nonprofit who will, in turn, use the funds to plant trees or invest in renewable energy projects, thereby reducing emissions of greenhouse gases. My biggest concern is that there is no assurance to consumers that their funds are truly being used to offset carbon emissions. In fact, any individual, company or nonprofit can claim to sell carbon offsets, and the customer must trust that their funds are truly being used for that purpose. Today, there is no accepted industry standard or clear governmental requirement to verify, or require verification, of such claims. I recently went online to a popular search engine, entered the words "carbon offset," and 10 Web sites appeared as sponsored links. At least one nonprofit organization dedicated to preserving rainforests was paying for this advertising. Their Web site did not provide a clear description of how a contribution for offsets would actually be used; did it clearly differentiate such a contribution for offsets from a straight donation to the organization; and did not describe any third-party system to verify that the online donation was used for its stated purpose, that the project was undertaken, and that the project actually offset the particular number of tons of carbon emissions. This kind of information is essential for consumers to have and to weigh prior to making such a financial decision. The lack of such information may allow unscrupulous vendors to confuse consumers and could discourage consumers from investing in carbon emission reductions As an advertising agency, we have first-hand knowledge of how stringent it can be to develop ads for regulated industries like utilities and insurance programs. Each one has clear rules for offering programs to consumers that impose specific disclaimers and other requirements and include strong enforcement. When companies and their advertising agencies are clear about the law, there is less confusion and more consumer protection. Adopting clear rules for companies offering carbon offsets and requiring full public disclosure from them, including third-party verification and governmental enforcement of their claims, should be the foundation for FTC guidelines related to this area of green marketing claims. EnviroMedia Social Marketing is encouraged that the FTC is considering adopting new enforceable guidelines for marketing carbon offsets and renewable energy credits – and we urge the FTC to do just that. Of course, these issues are but part of the booming development and marketing of “green” products that remains largely unpoliced, despite some helpful early guidance from the FTC years ago. We hope that the FTC sees today’s green product boom as the right time to take up not only carbon offsets and RECs but also the broader set of green marketing claims. The FTC's January 8 public workshop examining carbon offsets and RECs is a great first step.