|Received:||2/11/2008 2:09:40 PM|
|Agency:||Federal Trade Commission|
|Rule:||Guides for the Use of Environmental Marketing Claims|
Comments:III. B. Specific Issues 4) The Guides do not currently provide sufficient guidance for recycled content claims for textile products, specifically not for pre-consumer content as it applies to synthetic polymers. Determining pre-consumer content in synthetic polymer production seems to be especially difficult because these building blocks of textiles are also "plastics" and the same raw materials can be formed into plastic containers or textile components. Even thought there seems to be some similarity between the production of polyester, polypropelene, polyethelene, and nylon, we only hear pre-consumer claims being made about one polymer in particular: PET or polyester. These pre-consumer or post-industrial claims are based on a variety of ways of reutilizing either waste, or seconds, or "in between" grades of material. This pre-consumer material could take the form of chip, fiber, or yarn or bottle pre-forms, all of which can be reused in the production of polyester, a manufacturing process that has been able to minimize waste. It is my understanding that other polymers, polypropelene and polyethylene for instance, would be able to make the same claims of pre-consumer content if they were better defined. The current Guides give a variety of examples from other industries, none of which are very instructive where synthetic polymers are concerned. For instance, if a claim of pre-consumer content is only valid if the content came from waste, most synthetic polymer production processes would not qualify, because they have already minimized waste. If a claim of pre-consumer content hinges on a change of form, many polymers would qualify, because as production moves from chip to fiber to yarn, or to bottles/containers there is fall-out that can sometimes be returned to a previous stage or form. If pre-consumer content needs to have been created in a process different from the one in which it is used, that would further sort out the valid claims. I believe there are valid pre-consumer practices going on in a variety of different textile production processes, but without criteria to measure those processes against, some synthetic polymers are perhaps over-celebrated, and others are under-reported. III. B 5) I do believe there should be alternative mehtods of calculating recycled content, based on spreading recycled materials either throughout a product line or across several product lines, as this is one way to ensure that materials are not being downcycled. Recycled content can be difficult to incorporate and still maintain quality. For instance, manufacturers of greige goods for piece dyed textiles have been reluctant to adopt post-consumer recycled content since the irregular nature of post-consumer bottle re-grind can yield streaks or other off-shade characteristics in an unforgiving solid fabric. This same hindrance to first quality has kept post-consumer out of textiles for automotive. But by introducing small amount of post-consumer recycled content quality often can be maintained. This would argue for another yardstick that looks at how recycled content was successfully incorperated in first quality goods. If we insist on only measuring the product we will relegate some forms of recycled content to being "folded" into products made from a low quality mix of scraps.