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October 08, 2010

The FTC Wants Your Green Marketing Comments by December


Screen shot 2010-10-08 at 1.29.22 PM Ok green bloggers, here is your chance to influence governmental policy without going through that painful voting process -- the FTC wants to know what you think about the messaging on green products. In other words, how do you want them to put truth into green advertising via their Green Guidelines?  Go here to tell them, you have until December 10, 2010. 

Some example language...

• Marketers should not make unqualified general environmental benefit claims. They are difficult, if not impossible, to substantiate. (The current Guides state that marketers can make unqualified claims if they can substantiate all express and implied claims. Otherwise, they should qualify the claim.)

• Qualifications should be clear and prominent, and should limit the claim to a specific benefit. Marketers should ensure the advertisement’s context does not imply deceptive environmental claims. (In the current Guides, this guidance appears only in examples.)

Certifications and Seals of Approval

• This new section emphasizes that certifications/ seals are endorsements covered by the Commission’s Endorsement Guides and provides new examples illustrating how those Guides apply to environmental claims (e.g., marketers should disclose material connections to the certifier). (The current Guides address certifications/seals in only one example in the general environmental benefit section. 16 CFR 260.7, Example 5.)

• Because an unqualified certification/seal (one that does not state the basis for certification) likely conveys a general environmental benefit claim, marketers should use clear and prominent language limiting the claim to particular attribute(s) for which they have substantiation. (This provision highlights guidance already provided in current Guides’ Example 5.)

• Third-party certification does not eliminate a marketer’s obligation to have substantiation for all conveyed claims.

For the full write up go to http://www.ftc.gov/green.

These guidelines are extremely important as they become the backbone for all marketing material being created. It's one thing to be green and another thing to convey the attributes correctly and not mislead the public. 

The guidelines also cover:

  • Degradable materials
  • Compostable materials
  • Ozone-Safe / Ozone-Friendly
  • Made with Recyclable Materials
  • Free of AND Non-toxic products
  • Made with Renewable Energy
  • Carbon Offsets

Green is no longer a nice thing to do to create a new marketing edge. It is THE thing to do and we need a common, public way to talk about the accomplishments. 

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