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Sustainable Marketing Guidelines from the FTC

Posted by Chris Loughnane on Mon, Oct 11, 2010

The year is 1998. LEED has just been enacted by the newly formed US Green Building Council, the Dow Jones Sustainability Index doesn't yet exist, and odds are you have never heard the terms BPA, carbon footprint, cap & trade, or compact fluorescent.

Yet, even with all that's changed in the past 12 years-can anybody say Prius?-the growing market for green products is still being held back. It's like we said in our practical case for sustainability in product design,  people do truly want to buy sustainable products, but they just don’t believe anything that they hear.

Until now... hopefully.

You see, what has only just changed is that on Wednesday the Federal Trade Commission (FTC) proposed revisions and additions to their "Guides for the Use of Environmental Marketing Claims." These Green Guides exist to discourage marketers from making environmental claims that are unfair or deceptive.

So what arethe FTC's proposed revisions and additions? You can read the whole report,  a (lengthy) summary, catch the highlights below, or just know that the soul of the updates can be broken down into three words to marketers:

Show your work.

Environmental Marketing Claims


Eco-friendly is on the way out


[The Green] Guides caution marketers not to make blanket, general claims that a product is “environmentally friendly” or “eco-friendly” because the FTC’s consumer perception study confirms that such claims are likely to suggest that the product has specific and far-reaching environmental benefits.

Whether or not the marketer has deceptive intent seems to be irrelevant. What matters is what the FTC has determined what consumers think when they see general terms, and that these consumers expect more than they are getting.


One label to rule them all


While the FTC isn't backing any particular green label, they are cleaning house:

The [Greeen] Guides more prominently state that unqualified product certifications and seals of approval likely constitute general environmental benefit claims, and they advise marketers that the qualifications they apply to certifications or seals should be clear, prominent, and specific.

What the FTC is confronting here are OEMs using their own in-house green label (like SC Johnson’s controversy laden Greenlist) as opposed to an independent, third party label.

Side note: UL Environment is making a strong push to be that label, and their acquisition of TerraChoice (who we've covered before) makes them that much more of a favorite.

Don't be silly

For example, a company could make the logical argument that since (on a long enough time scale) everything is biodegradable, their product is biodegradable! The FTC says don't do that. The same logic applies to compostability and any other environmental claims.

New is harder

The public has a pretty good grip on sustainability mainstays like recycling, but when it comes to more recent, complex issues, like materials produced with renewable resources or carbon offsets, delivering a clear message may prove more difficult. Act with caution. I have to admit, as I was reading the report, I was a little surprised (disappointed?) at the gentle language being used by the FTC. I mean, misleading claims are so endemic to the sustainable product market that the only solution would seem to be a healthy dose of assertion, maybe even a little aggression. Well, it turns out the chairman of the FTC has a slightly more direct mentality:

In response to a question about how the commission plans to enforce the guidelines, Mr. Leibowitz said that he expected most businesses to comply, and added “for those companies that don’t, that fall on the wrong side of the final ‘Green Guides,’ we’re going to go after them.” New York Times

The days of coming up with a green marketing campaign after the product is already designed are numbered.

Topics: medical device regulation, sustainability, sustainable product design