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Upshot of FTC Revised Green Guides: Stop Touting Products as “Green”

3p Contributor | Tuesday October 16th, 2012 | 0 Comments

By Jacquelyn Ottman

It only took them 20 years (The first guides were issued in 1992), but then again, as the saying goes, every overnight sensation is twenty years in the making. Maybe the FTC Green Guide staff put in their 10,000 hours, and, at last, they nailed it. The revisions to the Green Guides, published on October 1, 2012, show that the FTC is finally putting their foot down (both of them) about the term “green,” along with such related generalized environmental claims as “eco-friendly” and “Earth smart.”

And while they’re at it, they’re advising against the use of any label, logo, seal or product name or image — what I like to call “daisies, babies or planets” —  that can imply any hint of environmental (or health) superiority without adequate scientific support. Because chances are such claims are nearly impossible to support, the risk-adverse will stay far away from suggesting same.

And just in time, too. Interest in green claims continues to swell despite tough economic times. As the global population climbs to an unimaginable 9 billion by 2050, we’ll no doubt find many more ways for consumers to “go green,” with accompanying eco-language to boot (will “Mars friendly” be next?). But for now, we’re all still here. So, hopefully, there’s still time to clean up the green marketing business so we can one day harvest the potential to lighten consumers’ size-18 planetary footprint.

The lawyers at the FTC did what “greening” requires everyone to do — to think holistically, acknowledging the need to back up environmental marketing claims with life cycle assessments. They obviously consulted with some smart ecologists and biologists because the revised Green Guides demonstrate a sophisticated understanding of sound science. The guides don’t explicitly state the science, but for us laymen, here’s a quick crib sheet that can help you understand why they’re saying what they’re saying:

There’s no such thing as a green product. Every product uses resources and energy and creates waste.

One attribute does not a green product make.  An Energy Star-certified compact fluorescent light bulb has a tinge of mercury (and as such requires a hazardous waste permit to landfill in quantities of five or more.) Organic strawberries grown in California and eaten in New York are responsible for creating so many greenhouse gases on the trip cross country, we might as well eat berries conventionally grown in New Jersey. Paper made from sustainably-certified wood still needs to be bleached and/or otherwise processed with dangerous chemicals and shipped to Staples.

Should CFLs not be Energy Star-qualified? Should strawberries destined to hit the road not be labeled organic? Should paper that’s on its way to be bleached not be described as “sustainable?” Definitely not! Let’s simply be more specific, as FTC recommends, and not suggest they are totally “green.”

100 percent recycled content can be less “green” than 10 percent recycled content.  Depending upon the nature of the recycled content and how far it must be shipped to a recycling center, environmental costs of shipping and other impacts can actually make a recycled product less “green” than a virgin counterpart.

Natural is not necessarily green or more healthful. Arsenic is naturally occurring.

Sustainable is a moving target. Corn may be in plentiful supply today and able to be regrown year after year, but when water supplies wane, it may not be so “sustainable” to continue to grow it, no matter how fast or how economically it can be converted into bio-plastics and biofuel.

So, green is a relative, rather than absolute, measure. The best way to determine relative greenness is a bona fide life cycle assessment covering all facets of a product’s environmental impacts, from raw materials procurement straight through to disposal. This is duly acknowledged in the latest installment of the FTC Green Guides.

We are the next endangered species on the planet. The planet is not at risk, we are. (Yet another reason not to include images of planets in one’s advertising or to make grandiose claims about saving it.) This is not a political issue, but an issue of our future, and particularly that of our kids and their kids.

So it’s incumbent upon every marketer, manufacturer, retailer, producer, and everyone else in the supply chain and their stakeholders to understand not just these guidelines and ideally their scientific underpinnings, but to do what we can to make all green marketing work as it’s supposed to.

We in industry — and concerned consumers, too — should get on the case of questionable green claims. In their infinite wisdom and thoroughness, the FTC provides lots of helpful information for marketers and to the public to make the process of reporting such claims easy. (The National Advertising Division of the Better Business Bureau can help too.)

Green marketing is just good marketing. As I’ve been saying for a while now — and it is admittedly counter-intuitive, the best green marketing doesn’t lead with a product’s “greenness.” The good news about many green(er) products these days is that, thanks to advances in design, materials and technology, they offer superior delivery on the primary benefits that consumers buy products for. So why not focus on those things instead of altruism and planets that don’t need to be saved?

At a minimum, consider that environmental marketing, reflecting the planet itself, encompasses so many potential product-related attributes, organic, VOC, recycled, and biodegradable, among them, as to render the term “green” meaningless. Rather than confuse, even deceive, consumers intentionally or unintentionally with messages about “eco-friendliness” and “natural” (which in their infinite wisdom, the FTC refused to define) why not hone in on those green-oriented terms that a now mass market seeks via all its segmentary splendor: “energy efficient”, “organically grown”, “water efficient”, “recyclable”, among them, and render your marketing both relevant, targeted, and credible? (FTC would love you for being specific.)

Moreover, let’s link those same “green” attributes to the benefits they deliver to consumers. For instance, let’s tout all things “water efficient” as “cost effective,” and “fuel efficient” as “convenient” (fewer fill-ups and the ability to drive in the HOV lane).

Does this mean we should not talk about “the environment” at all?  Not in the least!  Consumers still want specific, well-documented and genuinely helpful environment-related information — so let’s include them in our marketing messages in a secondary or tertiary place in line with its importance on our customer’s shopping list.

All of us environmental types like to talk about how, “if we do our jobs right we’ll put ourselves out of business.” Well, before we get run out of town for more greenwash and hogwash by a now enlightened FTC (and the Enforcement Division that stands ready to pounce), let’s agree to put ourselves out of the “save the planet” business and into the business of saving our customers some money, time, etc. in an environmentally sound way — and make our marketing more legitimately green for our bottom lines, rather than our faces red with shame.

Jacquelyn Ottman is principal and founder of the New York City-based J. Ottman Consulting, expert advisers on green marketing to Fortune 500 sustainability leaders as well as several U.S. government labeling programs. The author of four books on the subject, her latest is The New Rules of Green Marketing: Strategies, Tools, and Inspiration for Sustainable Branding (Berrett-Koehler, February 2011).


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