|Received:||2/11/2008 12:14:18 PM|
|Agency:||Federal Trade Commission|
|Rule:||Guides for the Use of Environmental Marketing Claims|
Comments:1.The Guides should include guidance regarding renewable energy and carbon offset claims to prevent misleading, inaccurate claims and practises. The purchasing and selling of renewable energy certificates and carbon offsets is not regulated and caution must be used when purchasing. Consumers should be protected and feel confident in their purchases. 2. The word sustainable is vague and overused. It should not be utilized unless the term is clearly defined by the FTC. The term means different things to different people and currently if it is used it's misleading. I do not think any current product is truly sustainable (meaning, from my perspective, no net environmental impact). A life cycle analysis per ISO 14040 guidelines performed by a qualified expert showing no net environmental impact would support the claim. 3. Yes, the Guides should define "renewable" as in renewable materials. A renewable claim could be supported by documentation showing the material can be "renewed" with in a ten year cycle or whatever it is defined to be. 4. No. Textiles are not well defined. An item should be specified either as reused/refurbished or recycled from the waste stream. Consumers have the right to know if a product is reused/remanufactured or has been recycled into a new product when purchasing. 5. The Guides should only specify one method of calculation for recycled content (based on the annual weighted average for the product). It would be misleading for a manufacturer to calculate recycled content across many or all of its product lines. For example, if a manufacturer produced two product lines, one with 50% recycled content, the other with 0%. It would be misleading to claim both products contain, on average, 25% recycled content. A consumer should have the right to know what the actual recycled content is in the item they are purchasing. Otherwise, claims could become misleading and an avenue is provided for making inaccurate, misleading claims. 6. It is difficult because many things won't breakdown for a long period in a landfill or otherwise, unless provided oxygen and sunlight. If a test method could be specified, it might help qualification of such claims. The Guides should be reviewed and revised as needed. They are very critical and enable consumers to make well informed product choices. Consumers have a right to accurately know the attributes of the product they are purchasing. More enforcement of the Guides is necessary so that inaccurate, misleading claims can be reported and corrective action taken. Businesses benefit from the Guides because they help maintain fair competition and truthful advertising. Cost of compliance with the Guides should be minimal and companies must be required to have accurate data to back up product claims.