The revised FTC Green Guides contain numerous modifications and new sections. Here are some important changes that custodial managers need to know:
General Environmental Benefits: If using broad terms such as “green” or “environmentally friendly,” there needs to be specific claims qualifying it.
Certifications: Seals of approval and certifications will need to specify if they are from a manufacturer or industry association. If environmental benefits are unclear from the seal, claims will need to be substantiated.
Compostable: All materials in the product or package must break down in the same time as the materials it will be composted with. Also, composting facilities must be available to a majority of consumers where this product is sold.
Degradable: The entire product or package must completely break down and return to nature within one year.
Free-Of: If a product claims it is free-of a harmful ingredient, there can’t be another substance that poses a similar risk. In addition, it’s deceptive to say its free-of an ingredient that is not associated with that type of product.
Non-Toxic: If claiming a product is non-toxic, there needs to be “competent and reliable scientific evidence” that the product is both safe for people and the environment.
Ozone-Safe: It is deceptive to misrepresent that a product is ozone-friendly or safe for the ozone layer or atmosphere.
Recyclable: Recycling facilities need to be available to at least 60 percent of communities where the product is sold, otherwise qualify that the product may not be recyclable in that area.
Recycled Content: Claims must specify what percentage of the product or packaging is made from recycled content.
Refillable: A method to refill the package must be available in order to make this claim. For example, the manufacturer must offer a refill for the original package or a system to collect and refill the package.
Renewable Energy: Claims must specify what percentage of the manufacturing process is powered with renewable energy if less than 100 percent. The Guides also recommend prominently specifying the type of renewable energy used.
Renewable Materials: To avoid confusing this with “recyclable,” “recyclable content” or “biodegradable,” claims must spell out the renewable material clearly and prominently and explain why it is renewable.
Terms such as “sustainable,” “natural” and “organic” were not addressed in this new version of the Green Guides. While this might leave the door open for some marketers, the FTC has made it clear that broad, non-specific claims are misleading and end users are advised to consider them with caution.
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