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IDFA and Other Associations Support FTC Green Guides, Suggest Updates

Feb 19, 2008

IDFA and Other Associations Support FTC Green Guides, Suggest Updates

Responding to a request for comment, IDFA and five other associations last week expressed their continued support of the Federal Trade Commission's (FTC) environmental marketing guidelines, known as the Green Guides, but noted that it was time for needed updates. In joint comments, they requested expanded guidance on the use of seals, logos and certifications, and recommended supplements that would provide guidance on sustainability, renewable energy, carbon footprints and other related claims.

IDFA submitted the comments with the Grocery Manufacturers Association, the American Bakers Association, the Food Marketing Institute, the International Bottled Water Association, and the Soap and Detergent Association. The Green Guides, which outline general principles for processors to use when making environmental marketing claims, were last updated in 1998.

"Fifteen years of changes in technology and science have opened opportunities for examples in the Guides to be enhanced to provide more useful and current guidance," the comments state.

For logos and seals, the comments ask the commission to include additional examples that would illustrate when qualifications are necessary. To clarify the use of certifications, the comments suggest emphasizing that "the certifying party must be truly independent from the advertiser and must have professional expertise in the area that is being certified" and adding another example to show when an advertiser would be required to ensure that third-party claims are substantiated.

Recognizing that new environmental concerns have spawned new terminology, the comments also urge the commission to develop supplemental guidance that would address emerging environmental benefit claims, such as renewable energy, carbon offsets, renewable energy certificates, carbon neutral, carbon footprint and sustainable.

"Consumers are interested in buying products with the new environmental benefits while businesses are eager to advertise their efforts in this areas," the comments state. "Without industry-wide guidelines relating to these new terms, however, advertisers may be reluctant to make such claims for fear that the claims may be allowed in some jurisdictions and prohibited in others."

In addition to submitting comments, IDFA has voiced concern that the practice of claiming an unjustified environmental benefit to create a positive impression, known as greenwashing, is garnering considerable media and regulatory scrutiny.

"If not abated, greenwashing could erode consumer confidence in bona fide green claims," said Clay Detlefsen, IDFA vice president of regulatory issues. "IDFA would like to see these important and motivating marketing claims preserved for legitimate use."

To read the comments, click here. For more information, contact Detlefsen, at or 202-220-3554.

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