Submission Number: 00016
Received: 10/12/2010 10:15:19 AM
Commenter: Carl Fuemmeler
Organization: Continental Products
Agency: Federal Trade Commission
Initiative: Guides for the Use of Environmental Marketing Claims; Project No. P954501
Attachments: No Attachments
After review of the proposed guides, I feel like the additions and changes are generaly very good. They are comprehensive and deal with many of the previously ambiguous and unanswered issues.
One very important aspect of the Guides for the organizations they pertain to is understanding that is it important and necessay that the Guides be followed, and that there are consequences if they are not followed. My company filed a compalaint through NAD (Mexico Plastic Co vs GP Plastics) in October of 2008. NAD found in our favor and advised GP to make several specific markedting changes. Essentially GP Plastics ignored the NAD advice. GP bet that there would be no follow up, no enforcement, and no consequences to their continuing to disregaurd the Green Guides and falsely market thier product as "GREEN". To this day GP contineues to make the same Green claims that violate the Green Guides. They have never been contacted by any enforcing agency.
Without enforcement against the obvious offenders (even the blatant ones such as GP who has been publicly exposed via the NAD) the Guides fail the harm those that follow and reward thse that take the risk to make false and misleading claims. The Guides can only be effective if the organizations that they pertain to have knowledge, ethics, and the willingness to follow, and know that failure to follow the Guides will result in real and meaningful consequences.