|Agency:||Federal Trade Commission|
|Rule:||Docket 9340; Proposed Consent Agreement In the Matter of The M Group, Inc., also doing business as Bamboosa, a corporation and Mindy Johnson, Michael Moore, and Morris Saintsing, individually and as members of the corporation|
Comments:I have read the FTC News Release dated 10/22/09 entitled Maker of Rayon Clothes Barred from Deceptive "Bamboo" Claims. I have a retail store in South Carolina, and our focus is providing consumers with environmentally-friendly products. I am pleased that the FTC is taking an interest in protecting consumers from 'greenwashing'. We share that concern and are faced daily with difficult decisions as to which manufacturers provide the 'greenest' option in a given category. As you are aware there are many factors to consider in assessing the overall environmental impact of a given item or article of clothing. We only carry clothing made from organic fiber or bamboo fiber. We appreciate the numerous, environmental benefits of bamboo. We also favor products made close to our store location by reputable companies who share our interest in protecting the environment. Given consideration of the various environmental pros and cons associated with the manufacture and use of clothing, we consider the Bamboosa product line to be a good fit for our environmentally-conscious consumers. We do want to ensure that we are accurately communicating the environmental pros and cons of our offerings so that consumers can make wise and informed decisions. In the article dated 10/22, the FTC contends that rayon from bamboo does not retain the antimicrobial properties of bamboo. This claim is made by many makers of various bamboo-based fabrics (e.g. clothing, sheets, towels). Our empirical evidence from employee and customer use of these products is consistent with the antimicrobial claims. And, Bamboosa has conducted independent studies demonstrating that their finished fabrics reduce rather than increase microbial counts. If the FTC has data or studies refuting the antimicrobial claims of rayon from bamboo, please publish or reference these studies for the benefit of consumers and for companies such as ours that do not want to mislead consumers. Also, the 10/22 article states the following: The Commission charged that the company's rayon products are not biodegradable because they will not break down in a reasonably short time after customary disposal. Most clothing and textiles are disposed of either by recycling or in a landfill, where such biodegradation does not occur. In the FTC guidelines on the use of the term biodegradable, there is not an example provided of a non-deceptive claim other than a shampoo product that is disposed of through the sewage system. It would be helpful if the FTC could provide an example of a solid waste product that could legitimately use the term 'biodegradable'. It is my understanding that nothing will biodegrade efficiently (or at all) in a typical landfill. It would be helpful if the FTC could improve its guidelines with regards to the term 'biodegradable'. Consumers are increasingly interested in composting, and many municipalities offer curb-based composting pickup. Therefore, it would be helpful if the FTC revised its guidelines so that there is product labeling that assists consumers in determining which products should be composted at the end of their useful life. Finally, it is not clear to me why the FTC has only chosen small companies making clothes here in the USA for this probe. Upon learning of the investigation, I called a large company selling bamboo fiber products made in other countries. They were unaware of the FTC actions in this matter. I believe the FTC can provide more consumer benefit by publishing and communicating clear guidelines to all manufacturers of bamboo fiber products rather than singling out a few small companies for a lawsuit.