PPB April 2015

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INNOVATE 30 • PPB • APRIL 2015
SEEING GREEN
substance if it never has been associ-
ated with that product category.
Non-Toxic
Marketers who claim that their
product is non-toxic need competent
and reliable scientific evidence that
the product is safe for both people
and the environment.
Ozone-Safe And Ozone-Friendly
It is deceptive to misrepresent that
a product is ozone-friendly or safe for
the ozone layer or atmosphere.
Recyclable
Marketers should qualify recycla-
ble claims when recycling facilities
are not available to at least 60 per-
cent of the consumers or communities
where a product is sold.
The lower the level of access to
appropriate facilities, the more a
marketer should emphasize the
limited availability of recycling for the
product.
Recycled Content
Marketers should make recycled
content claims only for materials that
have been recovered or diverted from
the waste stream during the manufac-
turing process or after consumer use.
Marketers should qualify claims for
products or packages made partly
from recycled material―for example,
“Made from 30-percent recycled
material.”
Marketers whose products contain
used, reconditioned, or re-manufac-
tured components should qualify their
recycled content claims clearly and
prominently to avoid deception about
the components.
Refillable
Marketers shouldn’t make unquali-
fied refillable claims unless they pro-
vide a way to refill the package. For
example, they can provide a system
to collect and refill the package or sell
a product consumers can use to refill
the original package.
If recycling facilities for a product
are not available to at least 60 per-
cent of consumers or communities, a
marketer can state, “This product may
not be recyclable in your area.” If
recycling facilities for a product are
available to only a few consumers, a
marketer should use stronger qualify-
ing language: “This product is recycla-
ble only in the few communities that
have appropriate recycling programs.
Made With Renewable Energy
• Marketers shouldn’t make unquali-
fied renewable energy claims based
on energy derived from fossil fuels
unless they purchase renewable
energy certificates (RECs) to match
the energy use.
• Unqualified renewable energy
claims may imply that a product is
made with recycled content or
renewable materials. One way to
minimize the risk of misunderstand-
ing is to specify the source of
renewable energy clearly and
prominently (say, ‘wind’ or ‘solar
energy’).
• Marketers should not make an
unqualified “made with renewable
energy” claim unless all, or virtually
all, the significant manufacturing
processes involved in making the
product or package are powered
with renewable energy or non-
renewable energy, matched by
RECs.
• Marketers who generate renewable
energy – say, by using solar panels
– but sell RECs for all the renewable
energy they generate shouldn’t
claim they “use” renewable energy.
Using the term “hosting” would be
deceptive in this circumstance.
Made with Renewable Materials
Unqualified claims about renew-
able material may imply that a prod-
uct is recyclable, made with recycled
content, or biodegradable. One way
to minimize that risk is to identify the
material used clearly and prominently,
and explain why it is renewable.
Marketers should qualify renew-
able materials claims unless an item is
made entirely with renewable materi-
als, except for minor and incidental
components.
“Our flooring is made from 100%
bamboo, which grows at the same
rate, or faster, than we use it.”
“This package is made from 50%
plant-based renewable materials.
Because we turn fast-growing plants
into bio-plastics, only half of our prod-
uct is made from petroleum-based
materials.”
Source Reduction
Marketers should qualify a claim
that a product or package is lower in
weight, volume, or toxicity clearly and
prominently to avoid deception about
the amount of reduction and the basis
for comparison. For example, rather
than saying the product generates
“10 percent less waste,” the marketer
could say the product generates “10
percent less waste than our previous
product.”
To view the complete Green
Guides, information for business, and
legal resources related to environ-
mental marketing, go to
business.ftc.gov. Find more articles
and information on corporate respon-
sibility under the Inside PPAI tab at
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