Glen Raven, Inc
Guides for the Use of Environmental Marketing Claims, Project No. P954501
Upon review of the Summary of the GreenGuide proposed update, I have written these comments: 1 - "Degradable" products should not be limited to one-year decomposition, as that arbitrary number is too restrictive - as many friendly materials won't degrade that quickly - especially in a landfill - where absence of sunlight and oxygen prevent even food scraps from degrading away. Even oak leaves will cover the ground in the forest for more than one year! Penn State researchers biodegradable plastics, which should be encouraged,and perhaps those products should be included in the consideration of a time frame. FTC cannot specify a time frame without a test method. FTC must investigate and publish the typical degradation periods for common materials to assist public comment and resolution. EPA provides some information, bpiworld.org provides information and reminds us that landfills prevent degradation of materials! 2 - "Renewable Materials" should not be a recommended Charateristic as renewable material definitions are not directly based on the Life Cycle Analysis of a product and do not recognize trade-offs for various impacts. Renewable does not equate to preferable. The definition of renewable is unclear in regard to many materials, including some textile fiber types. Renewable textile fiber types are usually treated with non-renewable chemistry which have undesirable environmental impacts. 3 - In future work, the GreenGuides need to address complex lablling issues for the textile and apparel markets. FTC Textile labelling rules do not allow for simple, concise labelling for such things as Recycled Content. This is true for yarn, fabric, and end products. A single label should be created that provides both the fiber content and the related environmental claims. Fabric and apparel product claims need to be allowed to exist at a "Product Line" level rather than an "Item" level, where it is not deceptive. For instance, different colors of fabric may use various colored yarns with different quantities of recycled material. It might be unfeasible to label every fabric item according to the yarn content that results from styling choices - but very fair to use weighted averaging of all items in the Product Line.