Submission Number: 00275
Received: 12/10/2010 4:07:58 PM
Commenter: Lynn Miller
Agency: Federal Trade Commission
Initiative: Guides for the Use of Environmental Marketing Claims; Project No. P954501
Attachments: No Attachments
To the Commission:
As a consumer of “green products,” an environmental activist, and an advisor to companies marketing products and services impacted by your guidance, I offer my thoughts on your proposed guidelines.
1. I suspect that your proposal to restrict the use of the terms “eco friendly” and “environmentally friendly,” while simultaneously deciding to avoid passing judgment on terms such as “sustainable,” “natural,” and “organic” may have the unintended consequence of leading all marketers who previously used the former terms to simply substitute the latter terms.
2. Since the terms “eco friendly” and “environmentally friendly” are in such common use, restricting those terms will require marketers to revise large quantities of marketing materials (in and of itself a practice that is not environmentally friendly!). Any guidance you issue here should be extremely explicit – with examples –to minimize any confusion in the marketplace.
3. The issue of private certifications is one of the most confusing parts of the green marketing landscape. I used to think it was just consumers who were confused, but when I attended a professional meeting run by the Soap and Detergent Association, I learned that manufacturers are just as confused as consumers. There are 100s of these “certifications” – even thousands worldwide – with no set standard of measurement. How are private certifications regulated? Which are meaningful? Which are not? Since label reading is the primary means by which consumers determine the legitimacy of a claim, it is critical that any label on a product stand for something credible.
4. I believe you need to strengthen the regulation of the term organic. Under the USDA Organic NOP standards, companies must pass very stringent tests in order to carry the USDA Organic seal. Yet in other sectors, any producer can call a product “organic” with minimal organic content. This is extremely confusing to consumers, as well as unfair to legitimate organic producers.
5. 5. Your decision to defer judgment on Life Cycle Analysis should not be put off indefinitely. LCA has the potential to revolutionize standard measurement of a product’s environmental impact, thus helping consumers and manufacturers to make better decisions. Please consider issuing a statement regarding your plans to address LCA more completely.
Thank you for your consideration.