|Received:||2/10/2008 12:37:12 PM|
|Organization:||Business for Social Responsibility (BSR)|
|Agency:||Federal Trade Commission|
|Rule:||Guides for the Use of Environmental Marketing Claims|
Comments:(A. General Issues) (1) Continuing need: Yes – more than ever. Claims about environmental attributes are proliferating, and although consumers are more interested in companies’ promises, buying decisions are stunted by a lack of generally accepted rules to compare performance by. At the same time, leading companies complain that competitors use “environmental marketing” to compete not on innovation, but instead only on messaging. In general, both companies and customers lack a common platform to communicate and improve by, and so there is a great need for objective guidance toward creating common language, assumptions, definitions, metrics and boundaries. Given emerging technology and changing business practices and impacts, this will be an ongoing and dynamic challenge. (2) Benefits to consumers: Companies are increasingly transparent, but customers are constrained in interpreting their messages by “bounded rationality” – that is, they don’t have time to sort out claims to decide what is relevant or factual. Thus, consumers benefit from having critical dimensions summarized by an objective party. This remains a great outstanding need. (3) Modifications to increase benefits consumers/(10) Modifications to increase benefits to businesses: Both environmental claims and our understanding of lifecycle impacts have become more complex. Thus, the Guides should consider i) broadening to deal with supply chain impacts more comprehensively, ii) industry-focused guidance, and iii) environmental issues including climate, water, land use/biodiversity and environmental health/toxicity. (15) Unfair or deceptive claims not covered: The report, “Six Sins of Greenwashing,” by Terrachoice does a fair update, though it will be important to confirm its findings. (16) Modifications to account for changes in technology: Although traditional product “labeling” remains important, information technology is changing the way that customers interface with environmental information. Labeling is becoming both more digitally-centric and remotely accessible, which means that environmental claims will trend towards dynamic, audience-targeted presentations backed up by information databases. Technology is also allowing better tracking of chains of custody via RFID and chemical marking, which means that the type and amount of information being communicated will grow more complex. In order to keep pace, the Guides might consider a supplementary forum akin to a “wiki” that would allow continuing updates of best and emerging practices for environmental information technology. (B. Specific Issues) (1) Whether to include guidance on renewable energy or carbon offset claims: Yes. Most claims around both – particularly carbon offsets – are based on dubious definitions and non-standardized assumptions, especially around communicating lifecycle impacts and boundary-setting. (2) Whether to include guidance on ‘‘sustainable’’ claims: Yes. “Sustainable” has strong currency in theory and economics, but it is difficult to interpolate meaningfully to single actors, because specific single things are generally not, nor should be, infinitely persistent. Instead, it is often used as an approximate synonym for “environmentally friendly,” so the Guides should help clarify these definitions and distinctions. Next, in defining “environmentally friendly,” there are infinite possible issues, so it is important to provide guidance on material issues by industry (for example, to Information and Communications Technology, which is characterized by complex physical supply networks, energy-intensive manufacturing and products, and toxics associated with products’ end of life). Note: BSR is publishing a business brief on “eco-promising” in March that it will be happy to share with the Guides upon request. Also, BSR provides existing business guidance on “Getting Carbon Offsets Right” (www.bsr.org/reports/BSR_Getting-Carbon-Offsets-Right.pdf).