Submission Number: 00161
Received: 12/9/2010 2:52:17 PM
Commenter: Jeff Swain
Organization: Webster Industries
Agency: Federal Trade Commission
Initiative: Guides for the Use of Environmental Marketing Claims; Project No. P954501
Attachments: No Attachments
To Whom It May Concern:
As a leader in the recycled can liner marketplace Webster Industries has been producing can liners with recycled content for over 37 years. Within our industry we see a log of environmental claims, many of which are misleading, vague or often outright false. Many of these claims are around “degradable” can liners ability to degrade in land fill which you have outlined as being false and yet we still see such products on the market.
We applaud and fully support the new proposed green guidelines as they are written. We feel that it is irresponsible to make vague or misleading statements. It is for this reason that Webster Industries does not make degradable products or claims. Webster Industries clearly marks all of our recycled products with the exact recycled content and communicate the benefits of recycled can liners vs. virgin plastic.
Our only additional comment as a company is to encourage you to require as many specifics as possible for claims being made as well as setting guidelines for such claims. For instance with recycled content claims some companies may claim 100% recycled content which can be vague and is often untrue. Colorants and other additives are required to make can liners so they are never 100% plastic. What the 100% recycled claim is saying is that 100% of the plastic content may be recycled plastic which is a totally separate statement as only 90% of the can liner may be plastic. The other 10% is often made up of additives and colorants. As a responsible company Webster Industries quotes 75% recycled content which is the percentage of the total product (weight) that is recycled plastic (25% is made up of colorants, additives and other plastics). We feel that this needs to be clearly differentiated so as not to mislead consumers with regard to what they are actually buying. This can be carried over to paper products and many other items. Are tissues really 100% recycled or are bleaches and other additives used? Under today’s guidelines we do not know, but we hope to in the future.
The Webster Industries Team