Going Fair Trade
January lO, 2011 By Hand Mr. David Vladeck, Director Bureau of Consumer Protection Federal Trade Commission 600 Pennsylvania Ave., N.W. Washington, D.C. 20580 ~: Request for Investigation of Deceptive Practices in Advertising and Labeling _ as "Fair Trade Certified" of Certain Personal Care Products Dear Mr. Vladeck: Pursuant to the Commission's Rules, 16 c.P.R. §2.2, the Organic Consumers Association ("OCA") and All One God Faith, Inc. d/b/a Dr. Bronner's Magic Soaps ("Dr. Bronner's"), respectfully request the Commission to institute an investigation of the blatantly deceptive labeling as "Pair Trade Certified" of certain personal care products, in violation of section 5 of the Federal Trade Commission Act. The deceptive practices at issue are those of (1) The Hain Celestial Group, Inc. ("Hain"), makers of the "Queen Helene" brand of body cleansers and lotions; (2), Avon Products, Inc., makers of the "Mark" brand of cosmetics and personal care; and (3) TransFair USA, the certifYing organization that has authorized the misleading and deceptive labeling and advertising of "Queen Helene" and "Mark" brand products as- "Fair Trade Certified" when in fact the products so labeled contain a minor amount of fair trade certified ingredients. I. Fair Trade Labeling and Advertising The tenn "fair trade" is used to denote ingredients and products, particularly agricultural products, that have been purchased from cooperatives, collectives or other groups of farmers in developing countries, who have been paid a guaranteed minimum price plus a fair trade "premium" for community development projects; who treat their farm workers in accordance with recognized standards for achieving safe and healthful working conditions; and who commit to using environmentally sustainable farming methods, among other things.
[Show full text]