| Comment Number: | 534743-00029 |
| Received: | 5/19/2008 3:39:40 PM |
| Organization: | National Advertising Review Council |
| Commenter: | C. Lee Peeler |
| State: | NY |
| Agency: | Federal Trade Commission |
| Rule: | Guides for the Use of Environmental Marketing Claims |
| Attachments: | 534743-00029.pdf Download Adobe Reader |
Comments:
The National Advertising Review Council (NARC) appreciated the opportunity to have the National Advertising Division of the Council of Better Business Bureaus participate in the Federal Trade Commission’s (FTC) second workshop on Guides for the Use of Environmental Marketing Claims (Guides). The National Advertising Division of the Council of Better Business Bureaus is the investigative arm of the U.S. advertising industry’s self-regulatory process. NAD seeks to ensure that claims made in national advertising are truthful, accurate and not misleading. It requires that objective product performance claims made in advertising be supported by competent and reliable evidence. NAD cases can be initiated through staff monitoring of advertising claims or through “challenges” to advertising claims filed by competitors, consumers, or public interest groups. NAD has issued nearly 30 decisions involving a wide range of environmental or “green” marketing claims, often requiring that the claims be modified or discontinued. These decisions provide valuable guidance to companies making environmental marketing claims. Each NAD case involves evaluation of the claims made in the advertising and labeling and the supporting evidence provided by the advertiser. Compliance with NAD decisions is voluntary. Nevertheless, NAD enjoys a high rate of compliance. Advertisers that either refuse to participate in the self-regulatory process or do not implement the NAD’s recommendations are referred to the government. Attached to this letter is a summary of NAD decisions that have examined advertising involving “green marketing” or related environmental claims. Respectfully submitted, C. Lee Peeler President and CEO, National Advertising Review Council EVP, National Advertising, Council of Better Business Bureaus