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Green Guides = Your Guide Agenda 1/7/2013 Green Guides = Your Guide (for Environmental Marketing and Product Responsibility) By Tonia Ho, MAS Agenda • What is Green? • What are the FTC Green Guides? • What are the revisions and updates? • How do they protect you and your clients? 1 1/7/2013 What is Green? What is the claim for green? How is it perceived by the consumer? What does it mean? Is it specific? Source: holcombe‐cottages.co.uk There is no clear answer, thus the FTC stepped in….. Green Guides Basics –Consumer Perception • Tell the truth. How do consumers understand claims? (covered under Sec. 5 FTC ACT) • Have substantiation for all express and implied claims, as marketers are responsible for both that may lack clear and specific information. Source: Julia Wright, MAS Green Guides Basics ‐ Protect the Consumer Objective to ensure truth in advertising • Consumer reach: – business to consumer – business to business • Applies to ALL forms of marketing claims – Packaging and labeling – Advertising – Promotional materials – In any medium (broadcast, POP, online, etc.) The guides are NOT to offer performance standards or ecolabels. 2 1/7/2013 General Environmental Benefit Claims • CONSUMER PERCEPTION CONTROLS: Marketers should not make broad, unqualified general environmental benefit claims. They are difficult, if not impossible, to substantiate. • BE SPECIFIC: Qualifications should be clear, prominent and specific. Marketers should qualify the general claims with specific environmental benefits to minimize consumer deception. – OVERSTATEMENT OF ATTRIBUTES ‐ Small or unimportant benefits should not be highlighted as consumers interpret benefits to be significant. – NO NEGATIVE IMPACT?? ‐ If the benefit is a result of a specific attribute, marketers should also analyze the tradeoffs resulting from the attribute to prove the claim. What claim is being made? Environmental Claims Updated and new sections include the following: • Certifications and seals of approval • Non‐toxic • Carbon offsets • Degradable • Made with renewable energy claims • Compostable • Made with renewable materials claims • Recyclable • Ozone safe and Ozone friendly • Recycled content • Source reduction • Refillable • Free‐of claims 3 1/7/2013 Certifications and Seals of Approval Certifications and seals may be endorsements according to the FTC Endorsement Guides: • Marketers should disclose any material connections to the certifying organization, which can affect the credibility of the endorsement. • Seals must clearly convey the basis for certification, as the seals are also likely to convey the general environmental bfbenefits. • If not, the seals should identify, clearly and prominently, specific environmental benefits (otherwise risk implied claims). • Third‐party certification does not eliminate a marketer’s obligation to have substantiation for all conveyed claims. Trans‐Mate is proud to offer a line of earth‐friendly Envrio‐ Mate products by Trans‐Mate are formulated with environmentally‐friendly ingredients that provide superior performance at an affordable price. Certifications and Seals of Approval • According to www.ecolabelindex.com – there are currently 432 ecolabels in 197countries. • 4 Ecolabels in the US and 16 in Canada ildiincluding: LiLeaping Bunny, Non‐GMO (Canada), USDA and Canada Organic, Energy Star/Energy efficient. Our Industry Certifications USDA Organic: Organic is a labeling term that indicates that the food or other agricultural product has been produced through approved methods that integrate cultural, biological, and mechanical practices that foster recycling of resources, promote ecological balance, and conserve biodiversity. Synthetic fertilizers, sewage sludge, irradiation, and genetic engineering may not be used. QCA: Quality Certification Alliance is an independent, accreditation organization whose mission is to elevate the standards by which industry firms that import and/or manufacture promotional products provide consistently safe, high‐quality, socially compliant and environmentally conscientious merchandise. FSC: Forest Stewardship Council (FSC) certification is a voluntary, market‐based tool that supports responsible forest management worldwide. FSC certified forest products are verified from the forest of origin through the supply chain. The FSC label ensures that the forest products used are from resppyonsibly harvested and verified sources. SFI: The Sustainable Forestry Initiative (SFI) 2010‐2014 Standard promotes sustainable forest management in North America through 14 core principles that promote sustainable forest management, including measures to protect water quality, biodiversity, wildlife habitat, species at risk, and Forests with Exceptional Conservation Value. GOTS: The Global Organic Textile Standard (GOTS) is the worldwide leading textile processing standard for organic fibers, including ecological and social criteria, backed up by independent certification of the entire textile supply chain. SEARCH THESE IN SAGE! 4 1/7/2013 Certifications in Sage Dropdown box listing different standards – TSA, CPSIA, GOTS, etc. Caution not verified! QCA Carbon Offsets and Renewable Energy Marketers should employ competent and reliable scientific and accounting methods to properly quantify claimed emission reductions and to ensure that they do not sell the same reduction more than one time. It is deceptive to misrepresent that a carbon offset represents emission reductions that have already occurred or will occur in the immediate future. To avoid deception, marketers should clearly and prominently disclose if the carbon offset represents emission reductions that will not occur for at least two years. It is deceptive to claim that a carbon offset represents an emission reduction if the reduction, or the activity that caused the reduction, was required by law. Carbon Offsets and Renewable Energy 5 1/7/2013 Carbon Offsets and Renewable Energy Carbon offset and carbon footprint calculators exist for the following: ‐ Air travel ‐ Shipping (i.e. EPA Smartway Shipper Program) ‐ CarbonFund.org Made with Renewable Energy • Marketers must purchase RECs (Renewable Energy Certificates) to match energy use from fossil fuels for unqualified energy claims. • They should specify the source of renewable energy clearly and prominently (i.e. wind or solar energy) to minimize consumer risk of misunderstanding. • “Made with renewable energy claim” may be used only if all, or virtually all, the significant manufacturing processes involved are powered with renewable energy or non‐renewable energy matched by RECs. • Marketers who generate renewable energy AND sell RECs for what they generate should not claim they “use” renewable energy. Promote renewable energy and empower people's hearts and minds with positive messages that show This retractable ballpoint pen has a shiny you're doing your part to help our planet's future. Our surface, available in transparent or opaque exclusive scale model Hybrid e.Turbine Fans generate a plastics. Equipped with refill 774. Green cool breeze and draw attention to get noticed. Solar certified through EMAS (EU ecological audit model requires sunshine or equivalent to power a small regulation) and ISO 14001. Produced with motor that spins the turbine's blades. Popular Hybrid 100% renewable energies and PVC free. e.Turbines perfectly connect energy conservation with your promotions in the coolest way! Made with Renewable Materials • Renewable material unqualified claims may imply that a product is recyclable, made with recycled content, or biodegradable. • They should specify the source of renewable material clearly and prominently and explain why it is renewable to minimize consumer risk of misunderstanding. • Marketers should also qualify any “made with renewable materials” claim unless the product or package (excluding minor, incidental components) is made entirely with renewable materials. 6 1/7/2013 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: “product generates 10% less waste” vs. the claim “product generates 10% less waste than our previous product.” Free‐Of Claims Marketers can make a free‐of claim for a product that contains some amount of a substance if: ‐ Product doesn’t have more than trace amounts or background levels of the substance ‐ Amount of substance present doesn’t cause harm associated with the substance ‐ Substance wasn’t added intentionally to the product The free‐of claim would be deceptive if replaced with another substance that poses a similar environmental risk. It may be deceptive to claim a product is “free‐of” a substance if it never was associated with that prodtduct category to bibegin with. Approximately 4500 products resulted in a BPA‐Free search in SAGE while 6700 products resulted in a search for lead‐free. 16 oz double wall insulated acrylic tumbler with straw. The double wall insulation in this tumbler is perfect for keeping your beverages hot or cold without impacting your grip. Includes a 9" straw with stopper so it won't fall out of the cup. Hand wash only, do not microwave. BPA and lead free, Prop 65 compliant. Measures: 4" x 6". They look disposable, but they are in fact reusable and incredibly stylish. Free‐Of Claims One Example from the FTC: A package of t‐shirts is labeled “Shirts made with a chlorine‐free bleaching process.” The shirts, however, are bleached with a process that releases a reduced, but
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