Is it too easy being green?
In Congressional testimony last month in a hearing called “It’s Too Easy Being Green: Defining Fair Green Marketing Practices,” Consumers Union weighed in on ways the Federal Trade Commission can help ensure green claims are meaningful. The FTC is currently deciding whether to update its Guides for the Use of Environmental Marketing Claims, or Green Guides, first issued in 1992.
CU believes the government could help provide guidance for green marketing in three main areas, including:
1. Eliminating or better defining meaningless label claims in the marketplace:
• Voluntary, general claims like “natural,” “carbon negative,” “non-toxic,” and “free range” have little to no meaning and no verification.
• There should be minimum meaningful requirements that these claims should have to meet (and perhaps disclosures about what they don’t have to mean).
• The type of verification (or lack thereof) should also be disclosed on the product.
• In some cases, like “natural,” the term is so vague and difficult to establish standard meaning that prohibiting the use of certain label claims may also be necessary toward reducing green noise in the marketplace.
2. Setting baseline practices for all green marketing claims:
• We believe that the best labels meet all of our criteria for good labeling. However, there should be a floor established that ensures full transparency of label programs and products that are labeled with green claims. For example, ingredient lists, where relevant, should be fully disclosed. There currently is no requirement for cleaning labels to disclose all ingredients and yet, the green cleaning marketplace is filled with claims.
• Other considerations for baseline practices could include verification requirements, accreditations (oversight of programs), and meeting minimum claim definitions.
3. Hold government labeling programs to high standards with regard to practice and standard setting and ensure independence of standards and verification:
• Government-based green labeling programs should be independent, represent the interest and input from a broad range of stakeholders.
• They should also have rigorous standards that evolve over time.
• Where a premium is associated, for example with Energy Star or Design for the Environment, standards required should have to go beyond legal requirements and only a certain small percentage of a product market should be awarded premium labels.
• As more of a product market can meet a particular claim, it should signal an indication that standards need to improve.
• Marketing claim programs should have appropriate accreditations, oversight and adequate verification.
• There should be full transparency of information including how individual products are certified, whether all product ingredients are disclosed to allow consumers to make the most informed purchasing decisions, especially when they are paying a premium; this is not currently the case for EPA’s Design for the Environment label.
• The label should have consistent meaning across product types, which may require multiple agency coordinated efforts when label claims straddle many product areas that fall under multiple agency jurisdictions.
RELATED LINKS:
Consumers Union Congressional testimony on green claims 6/09 (pdf)
FTC takes aim at deceptive green claims 2/09
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