Submission Number: 00110
Received: 12/2/2010 2:26:14 PM
Commenter: Susan Ulery
Organization: Select Quality, LLC
Agency: Federal Trade Commission
Initiative: Guides for the Use of Environmental Marketing Claims; Project No. P954501
Attachments: No Attachments
I urge FTC to recognize that the use of the word "organic" to brand personal care products is committing a fraud upon consumers and also undermining the NOP standard (unless, of course, the product qualifies for and is labeled pursuant to NOP). Consumers usually don't read the fine print of ingredients on a label, and they believe marketing claims on the Principal Display Panel. They know we have a law about organic products, but they don't know that personal care products are operating outside that law. It is unfair to consumers to expect them to become labeling experts. They see "organic" and they think it's a true claim.
However, it is simply high-jacking and blatantly false for personal care companies to claim organic status for their products. The simple solution is for FTC to require truthful labeling. If personal care products meet NOP, they can make use of the claim and take advantage of organic branding. Most products won't qualify, but the manufacturers can truthfully make organic claims on the ingredient panel for individual ingredients that qualify.
Please help correct this fraudulent practice, and help consumers know what they're paying for. The abuse of the term "organic" just leads to more consumer confusion across all product categories, and seriously undermines the existing NOP system.