Submission Number: 00078
Received: 11/19/2010 9:28:30 AM
Commenter: Stacy Genovese
Organization: Good Housekeeping Research Institute
State: New York
Agency: Federal Trade Commission
Initiative: Guides for the Use of Environmental Marketing Claims; Project No. P954501
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I am writing from the Good Housekeeping Research Institute, home to both the Good Housekeeping Seal and the Green Good Housekeeping Seal. As an organization devoted to consumer product testing and consumer advocacy, we would like to commend the FTC on its proposed revisions to the Green Guides. We believe these new guidelines will help minimize the greenwashing and consumer confusion prevalent in today’s marketplace.
Last year, Good Housekeeping introduced the Green Good Housekeeping Seal, a green overlay to our primary Seal. In response to consumers who told us they were confused by the multitude of environmental claims in the marketplace, we have worked with consultants from Brown & Wilmanns Environmental to develop environmental criteria on a category-by-category basis. To date, we have finalized criteria and applications for the Cleaning Products, Beauty Products and Paints and Coatings Products categories and have seven more product categories in beta testing. You can find a detailed summary of the Green Good Housekeeping Seal application at http://www.goodhousekeeping.com/greenghseal. Our goal with the Green Good Housekeeping Seal is to help consumers cut through the muddle of modern day green advertising.
The Green Good Housekeeping Seal application includes an evaluation (and verification) of a broad range of environmental criteria, some of which is common to all product categories and some of which is specific to some categories. All applications include an evaluation of the materials, ingredients and composition of a product, energy, and water usage and waste generation associated with the manufacturing process, the packaging and distribution of the product, and corporate social responsibility. Product category-specific issues range from energy and water efficiency in use to end of life management. In light of the approach we have taken, which is similar to several other multi-attribute labels that recognize environmental and/or social responsibility performance, we would like to submit the comments in the attached document about the FTC’s proposed Green Guides and multi-attribute seals and certifications.
Technical and Engineering Director
Good Housekeeping Research Institute