Submission Number: 00307
Received: 12/10/2010 6:42:52 PM
Commenter: Travis Windleharth
Organization: Bekaert Specialty Films, LLC.
Agency: Federal Trade Commission
Initiative: Guides for the Use of Environmental Marketing Claims; Project No. P954501
Attachments: No Attachments
Bekaert Specialty Films, LLC (BSF), manufacturer of Solar Gard® window films is submitting this comment with regard to the Guides for the Use of Environmental Marketing Claims; Project No. P954501, pertaining to section IV. F. and V.2.a., regarding Life Cycle Analysis (LCA) and the eligibility of LCA results as marketing claims. In the discussion, it appears there is disagreement as to whether LCA should be a “decision making tool” (p.30) or the basis of a “marketing claim” (p.31).
BSF concurs with the expressed sentiment, “LCA information showing quantitative and specific environmental impact information in an advertisement positively influences consumers’ attitudes toward an advertisement, brand, company, and intention to purchase a product” (p.31). BSF also recognizes the importance of validating claims, and agrees with the FTC’s environmental claims substantiation clause, and believes this should extend to LCA as well.
Manufacturers that spend time and money to determine environmental impact in a transparent manner, should be able to leverage any realized environmental benefits determined by an LCA as part of their marketing efforts. Consumers deserve to know the environmental impact of the products they buy, in order to make more informed purchasing decisions. Allowing the results of valid LCA-based claims may help drive consumer demand for environmentally preferable products. This may, in turn, also drive more manufacturers towards environmental responsibility in the design, creation, and improvement of their products, in accordance with Environmental Protection Agency goals. Without such a marketing incentive for product comparison, manufacturers have fewer reasons to explore environmentally preferable manufacturing processes and products.
We believe that manufactures should back up their eco-claims, both for their internal use and in marketing efforts by being transparent about their processes. Specifically, we believe that:
a) Life Cycle Analyses not audited by a third party, or otherwise completed internally by a company, should be used strictly as decision making tools internal to the company that completed the study.
b) Only Life Cycle Analyses audited by a third party, and eligible for some manner of verified rating or formal report or certification, (such as an Environmental Product Declaration) should be eligible as the basis for marketing claims.
c) In general, all environmental claims should be specific as to the benefit achieved, and should be scientifically supported with third-party verified data.
In this manner, transparency is upheld while maintaining marketing incentives for beneficial LCA results. Indeed the company feels this matter of course would encourage process improvement within industries to improve LCA results, reducing overall environmental impacts of industry.
Bekaert Specialty Films, LLC. is committed to responsible manufacturing and business practices. In 2010, BSF completed two milestone projects at great expense of time and capital pertaining specifically to LCA. In May 2010, BSF achieved a Climate Declaration for 32 architectural solar control window film products, and in November 2010, BSF published its Environmental Product Declaration (EPD), completed to standard ISO 14040 and written to ISO 14025 standard for EPD reporting. Both the Climate Declaration and Environmental Product Declaration require a full, independently audited LCA. As such, LCA data was collected and analyzed by BSF staff and independent corporate sustainability consultancy, Altanova. The LCA data and resulting report was then peer reviewed by Five Winds International, and posted with EPD operators The International EPD Consortium in Sweden and The Green Standard in the United States. None of these aforementioned verifiers or EPD operators are materially connected to BSF.