|Received:||2/4/2008 6:57:05 PM|
|Commenter:||Sergio F. Galeano|
|Agency:||Federal Trade Commission|
|Rule:||Guides for the Use of Environmental Marketing Claims|
|Attachments:||533431-00007.pdf Download Adobe Reader|
Comments:Dear Sir/Madame: Georgia-Pacific LLC is one of the largest international manufacturers of forest products and chemicals for these products. Our manufacturing facilities are principally located in the United States, and the issues on environmental claims addressed in this broad solicitation of comments affect significantly our businesses and marketing efforts. Since the initial Green Guides in 1992 and subsequent updates, we have consistently commented on them as evidence of our interest on the subject matter. We commend the FTC for the timely review of the Guides in order to ascertain new environmental (and sustainability) claims that have been emerging in the last few years. We also caution the FTC that albeit not perfect, the present rules in the Guides have served business and consumer well. Thus, this opportunity should not be used to revisit already sound, approved and time-tested interpretations that are already integral part of the environmental marketing lexicon. There are few cases pending since 1998 and new ones requiring the expansion of the Guides along the same direction already established. Entirely new cases are few but challenging and our analysis of the review contents firmly makes us believe that the conventional, practical substantiation demanded on claims would go a long way in resolving the pending issues. We have used question (7) to group these new issues requiring attention and action by FTC. The rest of our comments in General and specific issues are contained in the attached pdf file.