|Received:||5/19/2008 12:00:10 AM|
|Agency:||Federal Trade Commission|
|Rule:||Guides for the Use of Environmental Marketing Claims|
Comments:I think sustainability or sustainable is such a challenging concept and so difficult to apply to dynamic and complex biological systems, such as a forest ecosystem, that the FTC should not permit its use in labeling claims. I recommend that "sustainable" not be claimed as something that is "achieved" in advertising or labeling forest products or for forest management systems. The public will likely have a concept of sustainable management as a process which retains all the natural functions and components ( flora and fauna) of a native forest. I doubt this is a claim that can be susbstantiated with confidence.