Environmental Marketing Claims

In 1998, the Federal Trade Commission issued environmental marketing guidelines, commonly referred to as “Green Guides.” These guides, along with existing FTC requirements for truth and substantiation of advertising claims, ensure accuracy of environmental claims. According to the National Advertising Division of the Better Business Bureaus, environmental claims have nearly overtaken superiority claims as the most scrutinized by the NAD. In February 2008, the FTC announced it is currently undertaking a regulatory review of the guidelines, in order to address new forms of environmental marketing.

AAF Position
The American Advertising Federation has urged the FTC to use caution and move slowly in any revision of the Green Guides. The advertising industry’s self-regulatory standards requiring truth and substantiation already apply to environmental advertising claims. We believe that a substantial revision of the guides could have a chilling effect on environmental advertising claims by creating confusion or uncertainty as to advertising requirements. A copy of the comments we submitted to the FTC is available here.

Some argue that while consumers want brands to play a larger role in improving the environment, they are often confused by environmental terminology. Because there is no single body of data on recycling efforts, it is difficult to substantiate very specific environmental claims. They maintain that revising the Green Guides, either to address more specific marketing claims, or to prohibit them, would alleviate confusion.

After announcing it would review the Green Guides in February 2008, the Federal Trade Commission held an environmental packaging workshop on April 30, 2008, hearing opinions from government officials, environmental group representatives and manufacturing and packaging companies. Many panelists agreed that changes were needed to the FTC’s Green Guides.

Last updated: Ocotber 2008

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