| Comment Number: | 533431-00050 |
| Received: | 2/11/2008 4:58:07 PM |
| Organization: | Shaw Industries group, Inc. |
| Commenter: | Steven Bradfield |
| State: | GA |
| Agency: | Federal Trade Commission |
| Rule: | Guides for the Use of Environmental Marketing Claims |
| Attachments: | 533431-00050.pdf Download Adobe Reader |
Comments:
One of the greatest influences on the role and scope of the Green Guides is the increase in eco-labeling standards that are being required by the marketplace for third-party verification of a wide variety of environmental attributes on both product and company levels. These standards range from straight-forward environmental metrics to full life cycle assessments. Advancements in technology and the marketplace requirements of such standards can make compliance with the current Green Guides difficult without the use of cumbersome or potentially confusing disclaimers. In other areas of environmental concern, the complexity of environmental impacts have changed public policies related to impact reductions and how they are measured. Renewable energy credits have broadened the investment in renewable energy sources by allowing companies to claim renewable energy use in a flexible accounting system based on offsets. Direct investment in renewable energy generation and use only "on site" would be much more limiting to development. Similarly, carbon credits have allowed companies to offset their emissions of carbon by purchasing credits generated through public and private credit development mechanisms. Direct investments in carbon emission reductions at site continue as technology and economics allow, but the use of credits has accelerated worldwide carbon emission reduction programs by creating fungible carbon credit markets. Shaw sees the need for a similar credit mechanism for recycled content accounting. As third-party certification requirements increase, accounting for recycled content has been limited by traditional chain of custody methodology (“Direct Measurement”) or simple 12-month averaging (“Mass Balance”). Both methods take a very simplistic approach to the recovery and reuse of recycled material. Advances in technology and industry consolidation into more vertically integrated operations have created both opportunity and challenge for companies like Shaw. Supply chain partners have become part of the company through acquisition. Direct Measurement of recycled content would require massive capital restructuring. Averaging across all production would yield a recycled content percentage too small to be meaningful as a purchasing decision variable to customers. Complex recycling processes now make it possible to divert post-consumer carpet from landfills and recover the backing and nylon 6 fiber for return to carpet production. Shaw's Evergreen nylon 6 depolymerization plant at Augusta, GA, is the only commercially-scaled nylon recycling facility using post-consumer carpet feedstock in the world. It currently recovers 100 million pounds of post-consumer carpet annually to make 30 million pounds of nylon 6 monomer, caprolactam. This investment by Shaw yields caprolactam that is identical in composition, but higher in cost than virgin caprolactam. However, it takes only 5 barrel of oil equivalents in combined mass and energy to make 1000 kg of caprolactam at Evergreen, whereas virgin caprolactam takes 10 barrel of oil equivalents in mass and energy to make 1000 kg from crude oil. In order to create a recycled content accounting method that uses a systems approach, Shaw proposes an allocation system which offsets recycled material in much the same way that renewable energy or carbon credits offset the results of site operations. In this allocation system (“Mass Allocation”) a recycled pound of caprolactam is allowed to be claimed as an allocated "offset" to certain of Shaw's "branded" Anso and EcoSolution Q carpet products . This "systems" approach to recycled content provides a continuous incentive to recycle more and more nylon and allocates the nylon credits to Shaw products where the higher cost of recycling is economically recovered.