Finally, FTC has issued it's updated guidelines for what appropriate environmental marketing claims can be made for products. A very nice summary is here. Guidance.
In concert with comments I submitted against general environmental claims, FTC says:
Marketers should not make broad, unqualified general environmental benefit claims like ‘green’ or ‘eco-friendly.’ Broad claims are difficult to substantiate, if not impossible.
Marketers should qualify general claims with specific environmental benefits.
Qualifications for any claim should be clear, prominent, and specific.
- When a marketer qualifies a general claim with a specific benefit, consumers understand the benefit to be significant. As a result, marketers shouldn’t highlight small or unimportant benefits.
- If a qualified general claim conveys that a product has an overall environmental benefit because of a specific attribute, marketers should analyze the trade-offs resulting from the attribute to prove the claim.
And Hooray! they didn't try to deal with "sustainable."
I like FTC's approach to logos and seals, too:
Marketers shouldn’t use environmental certifications or seals that don’t clearly convey the basis for the certification, because the seals or certifications are likely to convey general environmental benefits.
Not so happy they left the ability to say "free of" - which I think is often an unsubstantiated allegation of harm caused by the not-there chemical, rather than a simple statement that it doesn't contain a chemical.
The 300 page background document actually referenced my comments 38 times! Nice to be heard.
Still lots of room for interpretation, but an improvement. Now if they'll only enforce the Guides.
Contact EHS Strategies, Inc. for help keeping your claims compliant.