|Received:||5/17/2008 6:27:06 PM|
|Organization:||- independent consultant -|
|Agency:||Federal Trade Commission|
|Rule:||Guides for the Use of Environmental Marketing Claims|
Comments:I would like to strongly encourage the FTC to prohibit use of the term “sustainable”, and any claims related to the sustainability of a product, in all on-product or off-product labels or claims. I have closely followed the development and use of this term in policy arenas around the world for the last seventeen years, primarily in the field of forest management and forest certification. In my experience, the surest way to raise suspicion about the veracity of any claim on a forest product is to claim that it is “sustainable” or from a “sustainable forestry” enterprise. Promoting and working to achieve sustainability is one thing, but to claim one has actually achieved it or certified it is another matter altogether. Attainment of true sustainability is very difficult, particularly when dealing with complex ecological systems like forests, and thus very few who claim it currently attain it. Nevertheless, “sustainable” has become one of the mostly widely mis-used and abused terms in the environmental lexicon, and hence one of the most favored claims in ‘greenwash’ marketing – where unscrupulous companies and governments assert that their products or forest management operations are more environmentally benign than they actually are. The fundamental problem is that there is no widespread consensus on a definition of the term “sustainable”, particularly in fields involving the management of ecological systems and biological resources. Some believe the term has a very concrete and specific meaning with real-world bottom lines like ‘no extinctions’, while others feel it is simply an ‘approach’ or ‘process’ that seeks to ‘balance environment, society and economy’ - a virtually meaningless definition with which almost any form of environmental management could easily comply. There is a very wide variety of perspectives on both the practical and scientific meanings of this term. In the field of forest management, for example, some believe the term applies primarily to the ecological attributes of the forest, while others believe it pertains more to social and economic concerns outside the forest. Some believe the term implies the harvest of some type of forest product, usually a single product - timber, and that “sustainability” is mostly concerned with maintaining an even flow of that product from the forest. Others believe that sustainable forest management does not necessarily require the extraction of any product from the forest, and that the term applies expressly to the entire forest, as an integrated ecological whole, rather than to any single component or product of the forest. Some see sustainability as an ideal condition to strive toward, while others see it generically as simply "good" management. In practice, working definitions of the word “sustainable” are so dissimilar in terms of their actual on-the-ground manifestations that there is no definition on which there is anything remotely resembling consensus anywhere in the world. I have seen countless efforts to mis-appropriate and mis-define the term so that any form of forest management can comply. If a word is used as a marketing claim, and that word deals with a very complex set of variables, and there is such wide disagreement on the definition of that word, then all claims using the word are automatically suspect, almost surely misleading, and potentially fraudulent. The FTC has a responsibility to consumers to prohibit such claims.