Guides for the Use of Environmental Marketing Claims, Project No. P954501
Weyerhaeuser supports the Federal Trade Commission's direction in revising the "Green Guides." We appreciate the Commission's investment in consumer research and agree that the policy goal is to convey truthful and non-misleading information to enable informed choices, ideally in the direction of products with smaller environmental footprints. Weyerhaeuser supports the comments of the American Wood Council, the Sustainable Forestry Initiative, and the Keystone Center's Green Products Roundtable. Each of these comments goes into more detail on specific subjects. We offer our continued support to the Commission in the area of green marketing and our expertise on sustainable forestry, sustainable biomass production, forest products supply chains, and forest certification. We recommend the Commission invite further collaboration and research in the area of certification of commodities, especially the challenges associated with the necessary mixing of fungible goods, including wood and wood fiber as well as agricultural commodities, as they move through supply chains where process efficiency determines competitiveness. Innovative models are emerging both internationally and domestically to track, label, and trade in both tangible goods and intangible environmental attributes. These need to be encouraged but also challenged to convey truthful and non-misleading information to consumers as these new markets develop. Thank you for the opportunity to comment.