|Received:||2/11/2008 4:09:53 PM|
|Organization:||TerraChoice Environmental Marketing|
|Agency:||Federal Trade Commission|
|Rule:||Guides for the Use of Environmental Marketing Claims|
|Attachments:||533431-00040.pdf Download Adobe Reader|
Comments:As a firm dedicated to helping manufacturers of truly “green” products excel in the marketplace, we are alarmed at the increasing number of potentially false and misleading claims being used to promote products with tenuous claims to environmental responsibility. Phrases like “all natural,” “environmentally friendly,” “eco-friendly,” and “recycled-content” are routinely being used by product manufacturers who fail to provide any definition of the terms. They are using these and other vague claims in ways that are clearly misleading the public. Manufacturers are making claims about the environmental benefits of their products without providing any evidence to support their claims. They are also increasingly making accurate, but misleading statements to highlight relatively insignificant environmental benefits of a product while distracting consumers from much more significant impacts. As a result of these practices, consumers are unable to determine which products are more environmentally preferable. Consumers are being misled into buying products that falsely claim to provide environmental benefits. REASON FOR OUR CONCERN The opportunity for consumers to “vote with their wallets” and select more environmentally preferable products over their traditional counterparts is a potentially valuable market-based approach to address environmental issues. This market-based approach assumes consumers will be presented with accurate information to make their purchasing decisions. If consumers are instead presented with half-truths, vague claims, and other misleading information, the potential environmental and financial benefits of the green consumer movement will be squandered. Consumers will be spending their time and money supporting products that fail to deliver the environmental benefits consumers seek. SCOPE OF THE PROBLEM In an attempt to quantify the problem, TerraChoice reviewed the on-product claims of 1,018 products from six box store retailers. As the attached report explains, we found that all but one of the products violated what we call the Six Sins of Greenwashing. (1) Sin of the Hidden Trade-Off – Suggesting a product is “green” based on a single environmental attribute or an unreasonably narrow set of attributes without attention to other important, or perhaps more important, environmental issues. 57% of the products appear to commit this sin. (2) Sin of No Proof – Making claims without providing any substantiating information such as independent test data or third-party certification. (26% of the products) (3) Sin of Vagueness – Making a claim that is so poorly defined or broad that its real meaning is likely to be misunderstood by the intended consumer. (11% of products) (4) Sin of Irrelevance – Making an environmental claim that may be truthful but is unimportant and unhelpful for consumers seeking environmentally preferable products. The most frequent example is “CFC-Free,” an important environmental benefit but one that has been legally required for 30 years. (4% of products) (5) Sin of Lesser of Two Evils – Making “green” claims to promote unhealthy products or to promote the use of the products for unnecessary purposes. (1% of products) (6) Sin of Fibbing – Making untruthful statements such as falsely claiming a product has been certified by an independent agency. (<1% of products) RECOMMENDATION We encourage FTC to review the attached Six Sins of Greenwashing report and use its findings to help revise its environmental marketing guidelines. Specifically, we hope FTCwill: * Require marketers to provide independent proof of any environmental claim. * Prohibit marketers from suggesting that any single environmental attribute is sufficient to declare a product environmentally preferable without stating other environmental issues are important. * Clarify the existing requirement to make any and all environmental claims very specific.