|Comment Number:||536013-00061 (Revised version of 536013-00026)|
|Received:||9/11/2008 2:58:00 PM|
|Agency:||Federal Trade Commission|
|Rule:||Guides for the Use of Environmental Marketing Claims|
Comments:Comments for Green Building and Textiles Workshop – Comment, Project No.P084203 1. Please consider both organically grown fibers and recycled polymers as grounds for a green textile claim, recognizing textile dyeing and finishing as a separate issue. It is fair for consumers to understand if a portion of the product they are buying has been created in a more environmentally responsible manner. 2. Create the labeling requirement for new raw materials with a “green story” to be recognized as their generic names. For example, bamboo is very misleading as a green story because of the processing. It is still a polluting process that shouldn’t get a green textile claim when the process of making the fiber is problematic and should be labeled as rayon. Also included in this example are the soy raw materials. They should have an azlon label on them alerting consumers to the solvent spinning process. 3. Please do not allow "natural" or "renewable" claims to substantiate a green textile claim, since agriculture can have large-scale environmental impacts such as water and air pollution and soil erosion. Though these can be potential problems in organic agriculture as well, at least the criteria is defined for organic growing. Again, consumers understand what they are buying and claims of natural or renewable can still have practices that are not a net gain to the environment. 4. Regarding textile processing, such as dyeing and chemical finishing, reliable third-party certifications should be used to substantiate green textile claims based on "safer" chemical use, consideration of impact on employees throughout the supply chain and water/energy conservation. There have been suggestions that only the Global Organic Textile Standard (GOTS) be used for this process but that leaves out all the synthetic polymers. To avoid this, please allow this process to be open to other third party standards. Another leading one in the field is Bluesign Technologies and it is inclusive of all fibers and polymers. Please structure this part of the program in a similar way to the NOP accreditation program. There are specific criteria that must be met but there is more than one choice to achieve the criteria. Jill Dumain Director Environmental Analysis Patagonia, Inc.