FTC Releases Revised Consumer Brochure about "Green" Claims

A recent, informal surf of 150 Internet sites using environmental advertising claims found that most of them were in compliance with the Federal Trade Commission's "Guides for the Use of Environmental Marketing Claims." The surf, conducted by FTC staff, was announced to coincide with Earth Day on April 22 and the release of an updated edition of a consumer brochure on environmental marketing claims, Sorting Out "Green" Advertising Claims.

The full text of the brochure, which includes six tips for consumers, follows.

Sorting Out "Green" Advertising Claims

Grocery shelves, hardware stores, card shops, and other retail operations are filled with products and packages announcing environmental features that may influence your purchasing decisions. But when it comes to products and packaging, what do claims like "environmentally safe," "recyclable," "degradable" or "ozone friendly" really mean? The Federal Trade Commission (FTC) and the Environmental Protection Agency (EPA) want you to know.

The FTC, in cooperation with the EPA, has developed guidelines for advertisers to ensure that their environmental marketing claims don't mislead consumers. Here are six tips to help you sort through environmental claims.

Environmental Claims Should Be Specific.

When you evaluate environmental claims in advertising and on product labels, look for specific information. Determine whether the claims apply to the product, the packaging, or both. For example, if a label says "recycled," check how much of the product or package is recycled. The fact is that unless the product or package contains 100 percent recycled materials, the label must tell you how much is recycled.

Increasingly, labels on "recycled" products tell where the recycled material comes from. "Post-consumer" material comes from previously used business or consumer products, such as newspapers, shipping cartons, plastic bottles, glass containers, and aluminum cans. "Pre-consumer" material is basically manufacturing waste. For example, an envelope manufacturer might recycle the clippings left over when envelopes are cut from paper. These clippings could be made into other paper products instead of being thrown away.

"Recycled" products are made from items recovered or separated from the "waste stream" that are melted down or ground up into raw materials and then used to make new products. Or they may be products that are used, rebuilt, reconditioned, or remanufactured. If a product is labeled "recycled" because it contains used, rebuilt, reconditioned, or remanufactured parts, the label must say so - unless it's obvious to the consumer.

For example, a used auto parts store may sell used automobile parts that have been salvaged from other cars and label them "recycled" without any other description because it's plain that they are used parts. But an office copier that is labeled "recycled" because it was rebuilt, reconditioned or remanufactured - and then labeled recycled - must state that the recycled content came from rebuilt, reconditioned or remanufactured parts. That's because it may not be obvious that it contains used parts.

Some products and packages state that they use less material than former or competing products or packaging. To be meaningful, such claims should say exactly what's been reduced, by how much, and compared to what. For example, a claim like "20 percent less waste than our previous package" gives you more information than "20 percent less waste."

Certain products may claim to be "non- toxic," "essentially non-toxic," or "practically non-toxic." To make those claims, a manufacturer must have reason to believe that the products won't pose any significant risk to people or the environment.

Some Claims Are Too Vague To Be Meaningful.

Vague or general claims may sound warm and fuzzy, but generally offer little information of value. Claims that a product or service is "environmentally friendly," "environmentally safe," "environmentally preferable," or "eco-safe" or labels that contain environmental seals - say, a picture of the globe with the words "Earth Smart" around it - are unhelpful for two reasons: First, all products, packaging and services have some environmental impact, although some may have less than others. Second, these phrases alone do not provide the specific information you need to compare products, packaging, or services on their environmental merits. Look for claims that give some substance to the claim - the additional information that explains why the product is environmentally friendly or has earned a special seal.

There's Recyclable...and Then There's Recycled.

Recyclable claims on labels and advertising mean that the manufacturer or seller of the products has proof that the products can be collected and used again, or made into useful products. Some companies simply may say "Please Recycle" on their products. Such claims will be relevant to you only if these products are collected for recycling in your community, either through curbside pickup programs or drop-off programs. Contact your local recycling or solid waste officials for this information.

Some businesses recycle products for you. You may see a product labeled or advertised as "recyclable" and the business allows you to either return the used product to where it was purchased or send the used product to the manufacturer in a prepaid mailer. For example, some manufacturers of toner cartridges for computer printers allow consumers to return their empty cartridges to the dealer or mail them back to the manufacturer for reuse. Many grocery stores take back their plastic grocery bags. Check to be sure that the recycling program accepts the exact kind of product or package you want to recycle before you place it in the bin.

Degradable Products Don't Help Save Landfill Space.

Some products claim to be "degradable." "Biodegradable" materials, like food and leaves, break down and decompose into elements found in nature when they are exposed to air, moisture, and bacteria or other organisms. "Photodegradable" materials, usually plastics, disintegrate into smaller pieces when exposed to enough sunlight.

Either way, however, degradation of any material occurs very slowly in landfills, where most garbage is taken. This is because the law requires that modern landfills be designed to keep sunlight, air and moisture out of the landfill. This helps prevent pollutants from the garbage from entering the air and drinking water, but also slows decomposition. Even materials like paper and food may take decades to decompose in a landfill.

Cleaning products, like detergents and shampoos, often display "biodegradable" claims. Most of these products have always degraded in wastewater systems, causing no harm to the environment.

In contrast to landfills, "composting" takes advantage of degradability. Composting turns degradable materials into useable compost - humus-like material that enriches the soil and returns nutrients to the earth. Some people compost yard trimmings and food scraps in their backyards. Many communities collect leaves, grass, and other yard trimmings for composting. When you see a "compostable" claim on a product or package, it means the manufacturer should have made sure the material can be safely composted in home compost piles. If you want to compost a product in a community facility, check to be sure that your community facility accepts the material for composting.

All Ozone Is Not Alike.

Some products may claim that they are "CFC-free" or "ozone-friendly." But all ozone is not alike. The ozone layer in the upper atmosphere is necessary to prevent the sun's harmful radiation from reaching the earth. But when ozone develops at ground level, it forms smog, which can cause some people to have serious breathing problems. If a company claims that its products are "ozone friendly" or "ozone safe," it should have reason to believe that the products do not harm the atmosphere - either the upper ozone layer or the air at the ground level.

Chlorofluorocarbons - CFCs - are chemical substances that can deplete the earth's protective ozone layer in the upper atmosphere. In 1978, CFCs were banned for use as propellants in nearly all consumer aerosol products. They are gradually being phased out in all products and manufacturing processes.

If a product doesn't contain any CFCs, it doesn't necessarily mean it is safe for the entire atmosphere. Substances called volatile organic compounds - VOCs - also contribute to the formation of ground-level ozone, or smog. Alcohols, butane, propane and isobutane are common VOCs. How common are these VOCs? Emissions from cars and factories are the major source of VOC releases to the environment, but household cleaning products, floor polishes, charcoal lighter fluid, windshield wiper fluid, and hair styling spray, gel or mousse, whether in aerosol cans or spray pumps, also may contain these substances and contribute to smog problems.

Symbols Can Be Useful.

Certain symbols placed on consumer products tell you whether a product or package is recyclable (depending on your community program) or that the product or package is made from recycled materials

Symbol with chasing arrows

Many products display this "universal" recycling symbol, often called the three-chasing-arrows symbol. Some companies use it to mean that the product or package is made of recycled materials; others use it to mean that the product or package is recyclable. Since some communities don't accept for recycling every product or package that bears the symbol, it's a good idea to check with your local recycling or solid waste officials if you are unsure about appropriate disposal.

SPI Symbol

Manufacturers use this symbol, a code developed by the Society of the Plastics Industry, to indicate the type of plastic from which a particular product is made. SPI code numbers range from 1 to 7. Bottles or jugs labeled with numbers 1 and 2, such as soda bottles, detergent, shampoo, and milk jugs, are the most likely to be accepted for recycling. One caveat: Not all communities collect and recycle containers with the same codes, so it's a good idea to check with your recycling and solid waste officials for information on the codes that are accepted for recycling in your area.

For More Information

The FTC issued the Guides for the Use of Environmental Marketing Claims ("Green Guides") to prevent the false or misleading use of environmental terms in product advertising and marketing and reduce consumer confusion. For a copy of the Green Guides, visit www.ftc.gov and click on Consumer Protection or contact: FTC Consumer Response Center, 600 Pennsylvania Avenue, NW, Washington, DC 20580; 202-FTC-HELP (382-4357); 1-866-653-4261 (TDD for the hearing impaired).

For more information from the EPA, visit www.epa.gov or contact: U.S. EPA Pollution Prevention Information Clearing House, 401 M Street, SW (7409), Washington, DC 20460; 202-260-1023.

Copies of the Sorting Out "Green" Advertising Claims and the FTC's Guides for the Use of Environmental Marketing Claims are available from the FTC's web site at http://www.ftc.gov and also from the FTC's Consumer Response Center, Room 130, 600 Pennsylvania Avenue, N.W., Washington, D.C. 20580; 202-FTC-HELP (202-382-4357); TDD for the hearing impaired 1-866-653-4261. To find out the latest news as it is announced, call the FTC NewsPhone recording at 202-326-2710.