Submission Number: 00282
Received: 12/10/2010 4:39:50 PM
Commenter: Jeff Carrier
Organization: Carpet and Rug Institute
Agency: Federal Trade Commission
Initiative: Guides for the Use of Environmental Marketing Claims; Project No. P954501
Attachments: No Attachments
1. Seals and Certifications- Direction and limitation on the use of seals should be limited to clearly displaying the attribute promoted when practical on the packaging.
2. Seals and Certifications- S/C do not generally imply endorsement of a product/service by an issuing body. Endorsements are a different statement.
3. Recyclable- Rather than a static percentage of population reached by recycling activities, a combination of the supplier's activities, policy, and public resources should be considered in justifying a claim of recyclability.
4. Recyclable- Wider recognition of a product's recyclability (regardless of local or regional resources) would spur more entrepreneuers to engage in the process.
5. Recycled Content- We continue to believe that the distinction between post- and pre-consumer recycled content is the choice of the manufacturer.
6. Recycled Content- We continue to believe that weighted annual average is a valid measure of the recycled content of a product.
7. Free of/ Non-Toxic Claims- The term "de minimis" is counter to any system devised to ensure understanding, clarity, or specificity. It should be avoided in all circumstances.
8. Sustainable Claims- Distinction must be maintained between communications of an organizations sustainable efforts (philosophy, beliefs, activities, etc) and a product's sustainability impacts. Corporate claims of sustainability philosophy should not be included in this product based application.