Submission Number: 00201
Received: 12/10/2010 9:50:37 AM
Commenter: James Bogdan
Organization: PPG Industries
Agency: Federal Trade Commission
Initiative: Guides for the Use of Environmental Marketing Claims; Project No. P954501
Attachments: No Attachments
We are interested in the FTC’s proposal to define what a “reasonably short period of time” means with regards to plastic decomposition. The FTC has decided that public perception regarding a “reasonably short period of time” is no more than one year. This is an opinion and is not backed by any kind of scientific evidence. This “one year” rule will only apply to unqualified claims of biodegradability. For example, under the guidance of the proposed revision a company advertising a product as “biodegradable” would have to prove (if challenged) that the product would completely degrade in under one year. A company advertising a product as “completely biodegradable in 10 years” would not be subject to the revised guidance. Consequently, if this revision is accepted and included in the new guide it does not automatically spell disaster for companies advertising biodegradable products. We are concerned about the revision in that it might mislead consumers into believing that one year is “normal” with regards to the process of biodegradation. For example, wood is considered to be biodegradable but may take decades if not centuries to naturally biodegrade completely. As such, we believe that this revision will cause more consumer confusion than it alleviates.