Submission Number: 00040
Received: 10/29/2010 4:31:11 PM
State: New Jersey
Agency: Federal Trade Commission
Initiative: Guides for the Use of Environmental Marketing Claims; Project No. P954501
Attachments: No Attachments
Re: Comment to Environmental Marketing Claims - Project No. P954501
To whom it may concern:
I am writing to submit a comment for the Environmental Marketing Claims - Project No. P954501. As a consumer, I strongly support the Federal Trade Commission’s (FTC) proposed revisions to its Guides for the Use of Environmental Marketing Claims. However, the FTC should also add the term “sustainable” to the list of words that require companies to further qualify claims of environmental benefits.
When I entered “eco-friendly products” into a web search engine, the number of results reaches 2,070,000. Are there really this many eco friendly products on the market? As I click on a random sampling of products that claim to be “eco-friendly,” many sites do not explain why exactly the product is eco-friendly – just that the product is made from eco-friendly materials or an eco-friendly process. Because no one can really understand what “eco-friendly” truly means, parties who make such claims should be required to explain specifically what the environmental benefits are of their product. Further, these parties should use terms that the general public will understand, and not misleading buzz words that may mislead a consumer.
For example, I recently read an article about an airline that will be serving “eco-friendly” coffee that is grown on sustainably managed farms. After further investigation, I am lead to additional buzzwords such as the company is in accordance with environmental guidelines and is a member of a prestigious alliance. But shouldn’t all companies be in accordance with environmental guidelines? Additionally, I question what makes the coffee eco-friendly and what a sustainably managed farm is. I assume they are good things, which is probably what the company wants consumers to think without necessarily backing up such claims. I do not write to prove whether this particular company is indeed making proper environmental claims, but only to show how misleading these buzzwords can be to an average consumer who will likely not have the time to dig further into such environmental claims.
On a related note, the proposed revisions should have addressed the claims of “sustainability.” As seen in the above example, the variations of the word “sustainable” has a very comparable effect as the words “green” and “eco-friendly.” “Sustainability” is just as much of a buzz word as the other words the proposed revision is seeking to add more clarity too. Often, all of these words are used together. For example, when plugging in “sustainability green” into a web search engine, 8,250,000 results appear showing these two terms used together. While this is by no means to say that this type of test should be used as “meaningful guidance,” it does give an indication of how frequently the terms may be used together.
Thank you for your consideration of this comment.