| Comment Number: | 533431-00060 |
| Received: | 2/11/2008 9:16:54 PM |
| Organization: | Graphic Arts Coalition |
| Commenter: | Marcia Kinter |
| State: | VA |
| Agency: | Federal Trade Commission |
| Rule: | Guides for the Use of Environmental Marketing Claims |
| No Attachments |
Comments:
Feb. 11, 2008 To whom it may concern, Thank you for the opportunity to comment on the Federal Trade Commission’s Guide to for the Use of Environmental Marketing Claims. The Graphic Arts Coalition (GAC), comprised of the Specialty Graphic Imaging Association, Flexographic Technical Association, and the Printing Industry’s of America/Graphic Arts Technical Foundation, offer the following observations and comments. Our members are impacted by the outcome of this discussion, both in terms of production as well as use of input materials. Overall, we believe there is a continued need for these guides, and there is a need to publicize the availability as well as use of the guides within the consumer community. The questions raised in the Federal Register notice of November 27, 2007, are valid, however, we cannot substantiate with clear data, as none exists. The information we are providing is based on anecdotal information. And, this remains a key problem – no clear direction is provided to establish a positive flow of information. Our industry continues to seek a credible source of information regarding environmental marketing claims, and we believe that a revision of this document to contain stronger direction in the use of environmental marketing tools can become this source. Our comments focus on the benefit provided to the small business community. General Issues Question 7 Based on advertising claims being made, the following terms should be included in a revised version of the guide: Green, VOC Free, Eco-Friendly. These claims are being made without any substantiation. If the Commission is truly intending to enforce the use of environmental marketing claims, then the guide needs to be revised to include the terms that have been introduced since the last revision. Question 9. To date, the guides have not provided any benefit to the small business community represented by the Graphic Arts Coalition. The small printing facility is unaware of the availability of these guides and the information contained within. This is based on numerous conversations undertaken with key leaders in the printing industry. Daily, these industry leaders receive requests for “biodegradable” products or “compostable” products, or even “sustainable” products. When offered the opportunity to review the current guide, it is apparent from the responses that the existence of this guide is not known. Question 10. While the guide offers basic information regarding the definitions of terms, businesses are seeking clearer direction as well as benchmarks to establish clear use. For example, the guide states that “biodegradable” means that the product should break down in a reasonably short period of time. The business community is now asking for a clearer definition of “short period of time,” and oftentimes seeks a specific test method to verify the claims. Inclusion in the guides of acceptable test methods might be an appropriate next step. To date, we have not seen any costs, compliance or otherwise, incurred by our small business community as a result of the information contained in the guides. Question 13. At this time, the industry does appear to be abiding by the information found in the guides, however, the landscape for this type of product has changed dramatically, and the FTC needs to step up. It is hard to determine if there are deceptive claims regarding environmental attributes when the baseline provided does not include scientific baselines. Specific Issues Question 6. Yes, the Agency should provide more specific language regarding the use of terms such as biodegradable, compostable, etc. Before making a recommendation, the Agency needs to consider whether it will make a recommendation based on the final product, or the individual components. The interest and work in this area have rendered these guides obsolete. If not changed, we would recommend that they be discontinued. As currently written and in today’s surge towards sustainability, the guides fall short. We would encourage the Commission to consider holding public hearings and workshops on issues such as green marketing claims, and green labeling issues. Thank you for the opportunity to provide comment on this important document. To further discuss our comments, feel free to contact one of the parties listed below. Sincerely, Marcia Y. Kinter Vice President –Government & Business Information marcik@sgia.org Monteleone Director, Special Projects Flexographic Technical Association dmonteleone@flexography.org Gary Jones Director, Environmental Safety and Health Printing Industries of America/Graphic Arts Technical Foundation garyjgatf@aol.com