Guides for the Use of Environmental Marketing Claims #536013-00032

Submission Number:
LaRhea Pepper
Organic Exchange
Initiative Name:
Guides for the Use of Environmental Marketing Claims
RE: Comments to the FTC regarding the Green Building and Textiles Workshop ? Comment, Project No. PO84203. Dear Mr. Clark, By way of background, OE is a US-based non-profit organization which catalyzes market forces to expand the global organic cotton fiber supply. We work closely with farmers, leading brands and retailers and their business partners throughout the supply chain. OE has 267 members from 33 countries representing all parts of the supply chain, as well as service providers and other non-governmental organizations. OE is in the perfect position not only to witness and understand the kinds of claims being made on textile products, but also to disseminate the FTC?s labeling decisions domestically and internationally. We are firmly committed to preserving integrity of organic fiber products in a rapidly growing market. OE believes the Guides should be revised to provide business guidance, by addressing and permitting the truthful labeling of organic fiber products in the following key areas: Fiber Content Claims: Products with organic fiber content (including organic cotton, wool, linen, etc.) of any amount should be able to make a fiber content claim as long as the organic content has been certified by an independent third party. Organic Fiber plus Processing: While NOP addresses the production of organic fiber as an agricultural product. Certification for processing to make an ?organic product? claim is, at this time, voluntary. Equal consideration needs to be given to independent standards that support environmental stewardship for product processing. Examples of processing standards that should be considered are bluesign technologies, Oeko-Tex and the Global Organic Textile Standard (GOTS) or other such verifiable standards that cover post-harvest processing. ?Transitional Organic?: This is fiber that is grown organically according to the USDA NOP, but has not yet received organic certification, which only occurs 3 years after the last prohibited substance. The proof for such a claim would be that the farm has applied for organic certification; an initial on-site inspection has been conducted and the farm has an organic system plan which includes the last date of use of prohibited substances. There is need for a label that would truthfully represent the use of these fibers. Such a label would enable the organic fiber marketplace to grow while supporting the farmer during the three?year transition period. OE requests that FTC and USDA NOP discuss an acceptable label and guidance for use of such a label. Examples that should be considered: ?100% Transitional Organic Cotton (or other organic fiber)? or, ?Transition to Organic?. Blending Organic and Conventional Fiber: OE believes that it is important for brands and manufacturers to be able to claim whatever percent organic fiber they use in a product, as long the percentage is 5 percent or more and the claim is truthful and certified by an independent third party. Blended programs are an important transition that helps build consumer awareness of organic fiber and the efforts companies are going through to stimulate and convert the marketplace to more sustainable and environmentally responsible solutions. ?Reasonable Basis?: OE also believes the FTC should recognize third party organic certification as a ?reasonable basis? of proof of an environmental claim. Certification to organic standards is practiced worldwide, and is included in existing laws and regulations implemented by government authorities. The USDA NOP has a strong accreditation program to verify reputable certifiers that enforce the law governing the word ?organic?. NOP undertakes strict audits of certifiers and those that do not meet the standards lose their accreditation. Additional Background information and more in-depth comments are located in the attachment: OE FTC Green Comments 080708 Final