You Say You’re Green? OK, Prove It!

After more than 10 years, the Federal Trade Commission (FTC) has released proposed revisions to the “Green Guides” used to help companies apply “truth in advertising” when making environmental claims.

The new changes can be summarized in two words: Prove it.

Companies are expected to provide such proof in clear terms on the package, label or shelf so that consumers are not confused by any of the claims. Proof or qualifications should be clear or prominent and refer to only one specific benefit.

Claims of environmental benefits—such as “green,” “eco-friendly” or “environmentally friendly”—are considered too broad to substantiate. If you can prove that your product is “environmentally friendly,” you’re welcome to use the term.

Seals and certifications
There are hundreds of eco-labels in use around the world. Those seals and certifications that appear on packages, boxes, bottles and even menus are a form of “transparency by proxy.” Consumers want to believe that they represent some kind of endorsement of environmental attributes and that someone has validated or confirmed the claim.

There are really three kinds of “eco-labels,” according to the International Organization for Standardization (ISO):

• Type I—Voluntary, multiple-criteria based, third-party programs that award a license authorizing the use of environmental labels on products indicating overall environmental preferability of a product within a particular product category based on its life cycle.

• Type II—Informative environmental self-declaration claims.

• Type III—Voluntary programs that provide quantified environmental data for a product, under pre-set categories of parameters set by a qualified third-party and based on a life cycle assessment, and verified by that or another qualified third-party.

The new FTC guides propose these actions regarding seals and certifications:

• For voluntary, multiple-criteria based, third-party programs—such as those offered by trade associations or other trade groups: marketers should make clear that the programs are established by trade groups and define their relationship (subscriber, member, etc.) to the group.