Federal Trade Commission (FTC) Issues Updated “Green Guides” – What You Should Know

As consumers become more environmentally aware, the marketplace has stepped up to meet demand by competing for your attention with labels and badges claiming to be “eco-friendly,” “recyclable,” and/or “green.” But a new and improved product with “50% more recycled content” may not be what it claims to be if only 3% of its total makeup comes from recycled content. And what is actually “Recyclable” if a claim doesn’t indicate whether it is referring to the product or the packaging containing it?

The FTC is responsible for ensuring these types of environmental claims are qualified and therefore, in 1992 issued the first “Green Guides” to help marketers avoid making misleading environmental claims. It then revised the Guides in 1996 and 1998, and proposed further revisions in October 2010 to take into account recent changes in the marketplace. The new updates issued October 2012 take into account more than 5,000 total comments received since the FTC proposed revised Guides in the fall of 2010, reflecting a wide range of public input, including consumer and industry comments. The guidance they provide includes:

  • general principles that apply to all environmental marketing claims;
  • how consumers are likely to interpret particular claims, and how marketers can substantiate these claims; and
  • how marketers can qualify their claims to avoid deceiving consumers.

Here at Call2Recycle, as an active voice promoting the safe reclamation and recycling of batteries and cellphones, we promote green business practices and environmental sustainability. In doing so, we strictly adhere to and advocate the marketing guidelines outlined in the 2012 Federal Trade Commission “Green Guides” detailed below. The new edition includes:

    1. General Environmental Benefit Claims: General environmental benefit claims should not be made about a product if any part of the product is harmful to the environment.
    2. Certifications and Seals of Approvals: Use of a third-party environmental certification or seal of approval may still require marketers to clarify specific environmental benefit claims conveyed by environmental certifications.
    3. “Free-of” Claims: Only products that contain zero to an unintentionally-added trace amount of a substance should be marketed as “free-of” as long as the trace amount isn’t harmful to consumers.
    4. “Compostable” Claims: Compostable claims should be backed up with reliable scientific evidence stating that the product will break down; how long the degrading process will take; what it will break down into and what portion of this final product is usable or safe.
    5. “Non-Toxic” Claims: A non-toxic claim is accurate only if there is reliable scientific evidence that a product, package or service is safe for both humans and the environment.
    6. “Ozone-Safe” and “Ozone-Friendly” Claims: If any amount of a product, no matter how small, is harmful to the ozone layer, “Ozone-Safe” and “Ozone-Friendly” claims are deceptive.
    7. “Recyclable” Claims: A product or package is “recyclable” if it can be collected and/or separated from waste by established recycling practices currently in use for the purpose of manufacturing or creating another product.
    8. “Made of Recycled Content” Claims: A product is “made of recycled content” only if it made of recycled raw materials, used (but unchanged) components and/or reconditioned and remanufactured parts.
    9. “Refillable” Claims: An item is refillable if the consumer is provided with the means to actually refill the product, such as a company that sells a large-size bottle of hand soap alongside a refillable hand-soap dispenser.
    10. “Renewable Energy” Claims: A claim for “renewable energy” can be used if 100%, or nearly 100%, of the energy used to create a product is renewable.
    11. “Renewable Materials” Claims: A non-deceptive renewable materials claim details which portion(s) or amounts of a product are made with renewable materials.
    12. “Source Reduction” Claims: A product that is marketed as being reduced in weight, volume or toxicity should provide the exact comparative data between it and a previous version of the product or its competitors’ products.

As an example, Call2Recycle’s “RBRC Recycling Seal”is in compliance with these guides.

For other examples and to learn more about these and all of the current environmental marketing guidelines download the full FTC’s 2012 “Green Guides” for free at http://www.ftc.gov/opa/2012/10/greenguides.shtm

Call2Recycle® is a product stewardship program providing no-cost battery and cellphone recycling solutions across the U.S. and Canada. Operated by Call2Recycle, Inc., a 501(c)4 nonprofit public service organization, the program is funded by battery and product manufacturers committed to responsible recycling.