Submission Number: 00051
Received: 11/12/2010 12:45:11 PM
Commenter: Laura Lorincz
Organization: Sunshine Makers, Inc.
Agency: Federal Trade Commission
Initiative: Guides for the Use of Environmental Marketing Claims; Project No. P954501
Attachments: No Attachments
Sunshine Makers, Inc. supports the FTC in its efforts to update the Guides for the Use of Environmental Marketing Claims (“Green Guides”) and has two brief comments regarding the information within the current published draft.
1) The term “the environment” is used throughout the Green Guides, yet is not defined. Generally this term is associated with the physical quality of an ecosystem, though it also generally involves the impact to plant life and organisms that aid degradation. Most examples in the Green Guide that utilize this phrase seem to indicate that it is used in this manner. However, in § 260.9 (e) “…non-toxic for humans and for the environment…” we now deal with the concept of toxicity which is applicable only to living organisms and not physical states. We would request that the FTC clarify whether “the environment” does or does not encompass all flora, fauna and physical states of an ecosystem, thereby providing a clear definition for marketers.
2) Degradation testing standards, liquid and solid, as well as levels of degradation have been established by the OECD and the ASTM. It would benefit the FTC, as well as marketers of products sold in the United States, to align their standard of “100% degradation within 'short period of time'” with the testing standards used globally. It would also be beneficial to FTC, marketers and consumers to have the guidance structured to address various forms of products (liquids, solids, gasses) and to harmonize with global standards.