|Received:||5/19/2008 8:45:27 PM|
|Organization:||EnviroMedia Social Marketing|
|Agency:||Federal Trade Commission|
|Rule:||Guides for the Use of Environmental Marketing Claims|
|Attachments:||534743-00032.pdf Download Adobe Reader|
Comments:From January to May, 2008, more than 100 ads have been posted and evaluated by consumers on the Greenwashing Index at greenwashingindex.com. Below are three initial observations about environmental marketing claims for packaging, based on comments posted to this Web site, along with our 15-year experience working with corporations and government agencies on sustainability. 1. Enforce use of recycling and recycled content guidelines. The FTC has been absent for more than a decade in enforcing the existing standards for highlighting recyclability and recycled content. For example, a delivery truck (photo attached) carrying plastic bottled water has a billboard on it stating, "100% recyclable plastic," and "Go Green," and "Environmentally Friendly Bottles on Board." This confusing ad is only authentic if the truck delivers to areas which a) have a recycling program, and b) accept this type of plastic in its recycling program. The consumer may also be mislead to believe these plastic water bottles contain 100 percent post-consumer waste. A savvy green consumer may ask if the truck runs on alternative fuels, or question the natural source of the bottled water. 2. Every strategy possible is required to reduce energy production that increases greenhouse gases. The FTC should revise Green Guides to consider the energy required to make the packaging, and the product-to-package ratio. Voluntary efforts by major retailers addressing overpackaging are a great first step. However, a tremendous amount of energy and natural resources are wasted by thousands of products in the marketplace. 3. Companies that make claims about its carbon footprint should be required to list a Web site to substantiate those claims.