Submission Number: 00004
Received: 10/7/2010 11:12:34 AM
Commenter: Ruth Heil
Organization: The Write Beat
Agency: Federal Trade Commission
Initiative: Guides for the Use of Environmental Marketing Claims; Project No. P954501
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Thank you for the opportunity to comment. I am an average, middle-class, 12th-grade-educated, environmentally conscious consumer that supports simplicity in every answer. My answers may not have the detail you want, but I offer them as a way to help you understand my perceptions:
1.) Any claims to environmental improvement should apply to the product as a whole. No one should be able to claim their product is "green" because it was transported by a hybrid vehicle to the store after it used a wasteful, toxic process in its production.
2.) The bamboo illustration is very helpful.
3.) Honestly, the terms "green" and "eco-friendly" should be banned entirely, thanks to their history of abuse. Consumerism itself is neither "green" nor "eco-friendly" except in the rare cases when buying the product may be good for the Earth...at present I can think of none.
4.) The time period should be one year, and I felt this way before I read #5. All claims should require some sort of neutral party qualification.
5.) When I see "biodegradable," I hope that those agents will have degraded within a year.
6. & 7.) If a product says it can be recycled, it is up to me to find a recycler. My fellow consumers may not agree, but if I seriously want to recycle the item, I sometimes must go out of state. I would benefit, however, from a resource to tell me where I can drop off the item for recycling. If the manufacturer can't tell me where I can recycle it, they shouldn't be able to label it as recyclable.
8.) a3 and b: if an industry has created a standard process that diverts material from the waste stream, they should be rewarded for their efforts by being able to claim recycled content. Recycled is recycled, whether the practice is new or old. Long-time recyclers should not be penalized for a lifetime of logical practice.
9.) While some may still not understand, changes now will only lead to more confusion. I tried to reword "100% post recycled content" when I put the claim after "printed on" at the bottom of my letterhead, and could come up with no better way to say it.
10.) 100% post consumer recycled content should be 100%, 100% of the time. All claims should be qualified, especially since I pay a premium for recycled content, especially post consumer. See also #11.
11.) If a recycled content claim is made, it should always be followed by the percentage as it relates to pre- and post-consumer. A standard "for more information" line directing consumers to a legitimate educational resource would help the consumer who doesn't understand.
12.) I thought CFCs were banned, but every time I see the claim, I question myself. We've successfully moved beyond this...so too should advertisers. I support a ban on the claim.
13.) If it has nothing to do with the product's production, advertisers should not be allowed to reference it. Period.
14.) Organic should mean the product is entirely organic in all three scenarios. Is it hard to achieve? Absolutely, but only those that do should be allowed to make the claim. Organic has already taken a hard perception hit. Fewer people are trusting it today, but what else have the strictest among us got to go on especially when the manufacturer's contents are proprietary?
15.) Same as 11,
16.) I support the Center for Resource Solutions' Green-e certification.
17.) Few understand Carbon Offsets. Carbon neutral sounds like it sequesters any carbon it creates leaving a neutral result.
18.) Offsets should not be claimed until they occur.