Guides for the Use of Environmental Marketing Claims, Project No. P954501
sample comments (adapted from OCA), feel free to copy in part or whole: As an environmentally-conscious consumer, I appreciate that the Federal Trade Commission (FTC) is taking steps to address rampant green-washing in the U.S. marketplace. I welcome the opportunity to submit comments on "Guides for the Use of Environmental Marketing Claims," Project No. P954501. I am particularly concerned with shampoos, body washes and make-up that claim to be organic, but which are not certified to "USDA Organic" standards. I want the FTC to know that the misleading of consumers through “organic” claims is a serious problem. The main ingredients of these so called "organic" products are not made from organic material at all. Fake "organic" brands fool consumers by: * advertising only the organic, agricultural ingredients on their front labels * masking the petrochemical and synthetic ingredients by claiming that they are derived from agricultural ingredients, even though, under USDA organic standards, agricultural ingredients that have undergone a chemical change through contact with a non-organic substance are classified as synthetic and are disallowed * using a large number of organic ingredients in small amounts or counting the water content of organic ingredients to making it appear that the non-agricultural ingredients are minor or make up a small percentage of the total product, when, in fact, the non-agricultural ingredients are the main active ingredients and the organic ingredients are used only to provide scent or water content As a consumer I just want to know if the product complies with the USDA National Organic Program standards. It is clearly deceptive to call a product “organic” if it contains non-agricultural ingredients. In the proposed revised Green Guides, the FTC emphasizes that any given “green” claim must be specific and qualified. Applying that principle, when a personal care product contains minimal organic agricultural content but is labeled as if the entire product or at least the main ingredient is “Organic,” that labeling is exactly the kind of fraud that FTC is trying to address. Please do address these types of claims immediately! Thank you for considering my comments.