Guides for the Use of Environmental Marketing Claims, Project No. P954501
We appreciate the FTC’s diligence in working to assure the integrity of environmental claims and to protect consumers from the misrepresentation of products and services. Our comments reflect our experience as a food company with 27 years of experience in dialogue with consumers and environmental communications. Regarding "Made with Renewable Materials" Claims on Product Packaging: It's a huge challenge for food manufacturers to include all pertinent product information on small product labels, especially in light of Nutrition Label and Education Act (NLEA) labeling requirements. While we enthusiastically agree that additional information about product packaging is valuable to consumers, requiring manufacturers to include a number of qualifying statements on pack, would not be viable. We recommend allowing manufacturers/marketers to use the claim with the identification of the source material only. However, there should be required to reference a website where more detailed information about the renewable material exists. For example: “Renewable packaging made from plants.” Elsewhere on the package: “Learn more at [company website address]. Guidelines should provide some examples of simple language options manufacturers could use on pack, as well as, examples of qualifying claims to be used on the referenced website. Regarding General Environmental Benefit Claims (i.e. "green", "eco-friendly"): Prohibiting unqualified general environmental benefit claims entirely will undermine efforts to encourage consumers to buy or use products with lower environmental burden. An alternative approach which we propose is to have the FTC develop criteria for environmentally-preferable products that could be broadly labeled as “green” or “eco-friendly” These would be products that through their manufacture, use, and/or disposal have a lower environmental burden than the standard product it is replacing. This might include products made with a certain percent of recycled content, a low-toxicity cleaner, a stainless steel water bottle that replaces single-use bottled water, a reusable shopping bag, etc.