An Overview of the FTC’s Green Guides
Are you ready to embark on your company’s sustainability journey but unsure where to start? Join us on Wednesday, May 10, 2023 at 1 pm CST for an engaging, open-ended Q&A webinar designed to help businesses kickstart their sustainable initiatives. Nicole Sullivan, Director of Climate Services at CarbonBetter, will be on hand to answer your questions, share practical insights, and discuss actionable strategies for incorporating sustainability into your business operations.
Learn the art of ethical marketing and storytelling with guidance from the FTC’s Green Guides and our expert climate services team.
As businesses and stakeholders, including customers and investors, increasingly prioritize sustainable business practices, organizations must adeptly manage their environmental marketing claims, also known as sustainable marketing claims or green marketing claims, to ensure transparency and ethical communication. The Federal Trade Commission’s (FTC) Green Guides provide a comprehensive framework to support these efforts while keeping businesses informed about emerging greenwashing tactics. This article will provide an overview of the Green Guides, the recent public comment period extension, and how CarbonBetter can bolster your sustainability journey.
Background of the FTC’s Green Guides
The Green Guides, first issued by the FTC in 1992 and revised in 1996, 1998, and 2012, help marketers avoid making deceptive environmental marketing claims under Section 5 of the FTC Act by offering a clear set of principles for businesses to follow when promoting their products or services. The guides are codified as rule in the United States in Title 16 of the Code of Federal Regulations, Part 260. The FTC is currently reviewing the guides to determine if updates are necessary. These guidelines provide insight into how consumers interpret environmental claims and how marketers can substantiate them to avoid deception.
Why the FTC’s Green Guides Matter
Avoid Misleading Consumers About Your Environmental Impact
The Green Guides matter for businesses because they help address the risk of “greenwashing,” a practice where companies exaggerate or mislead consumers about their environmental impact. To maintain credibility and transparency, businesses should also stay informed of and avoid new and evolving greenwashing tactics, such as greenhushing, greenshifting, greencrowding, greenlighting, greenlabelling, and greenrinsing. Understanding these tactics helps organizations avoid misleading consumers and ensures they present an authentic image with accurate and verifiable sustainability claims.
Build Trust & Avoid Penalties
By adhering to the guidelines, organizations can ensure their marketing and storytelling efforts are transparent and accurate, fostering trust and loyalty among their stakeholders. Additionally, following the Green Guides can protect businesses from potential legal risks and penalties arising from deceptive environmental claims by providing a framework for substantiating and accurately representing their environmental claims. With regulatory crackdowns on greenwashing beginning in the European Union (EU), it is crucial for companies to stay compliant and maintain credibility with their stakeholders.
FTC’s Green Guides Decennial Regulatory Review
Recent Public Comment Period and Extension
The sustainability landscape has seen significant changes since the 2012 revision of the FTC Green Guides. As part of its routine decennial regulatory review schedule, the FTC launched a public comment period in December 2022. While initially set to end on April 24, 2023, the FTC extended the deadline to June 13, 2023, in response to the extensive feedback they received.
During this period, the FTC actively sought feedback on both general issues and specific topics that have garnered increased attention in recent years. These topics include carbon offsets, climate change, compostable and degradable claims, ozone-safe/ozone-friendly claims, recyclable and recycled content claims, energy use/energy efficiency claims, organic claims, and sustainable claims.
“Recyclable” advertising claims Workshop
As part of the Green Guides review, the FTC hosted a workshop on May 23, 2023, in Washington, DC, to discuss “recyclable” advertising claims. The free, public event, Talking Trash at the FTC: Recyclable Claims and the Green Guides, covered topics such as recycling practices, consumer perception of recycling-related claims, and potential updates to the Green Guides.
Applying the FTC Green Guides to Marketing and Storytelling
The Green Guides cover general principles and interpretation of environmental marketing claims, specific environmental claims (e.g., carbon offsets, compostable, degradable, non-toxic, ozone-friendly, renewable energy/materials, recycled content), third-party certifications and seals, and comparative claims. These sections mentioned above offer a comprehensive understanding of acceptable marketing practices for communicating sustainability efforts, including what is allowable when making a comparative product claim.
For a clearer understanding, we’ve compiled a table that outlines key strategies in line with the Green Guides, actionable insights for businesses, and how CarbonBetter can assist in each scenario:
How the FTC Green Guides and CarbonBetter Can Help You Make Accurate Environmental marketing claims
| Strategy | FTC Green Guides Reference | Actionable Insights | How CarbonBetter Can Help |
| Assess and update marketing materials to ensure compliance | Part 260: Sections 260.1-260.17 | 1. Review all marketing materials for environmental claims 2. Check for compliance with Green Guides standards 3. Update claims as necessary | 1. Provide consultation services to review and improve marketing materials 2. Offer guidance on compliant claim-making |
| Prioritize transparency and accuracy when making environmental claims | Part 260: Sections 260.2-260.9 | 1. Ensure all claims are accurate and supported by evidence 2. Disclose relevant information to consumers 3. Avoid vague or misleading language | 1. Assist in verifying environmental claims 2. Help develop clear and accurate messaging for consumers |
| Embed sustainability narratives within brand storytelling | Part 260: Sections 260.10-260.17 | 1. Identify key sustainability initiatives and achievements 2. Craft compelling stories that resonate with consumers 3. Integrate stories into overall brand messaging | 1. Support in creating engaging sustainability stories 2. Provide data-driven insights for compelling narratives |
| Partner with third-party certification bodies to bolster credibility | Part 260: Section 260.6 | 1. Research reputable third-party certification bodies 2. Apply for certification(s) relevant to your sustainability efforts 3. Display certifications and seals on marketing materials | 1. Recommend suitable certification bodies 2. Guide organizations through the certification process 3. Offer CarbonBetter certification services for additional credibility |
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This table serves as a roadmap for businesses to align their environmental marketing claims with the FTC's guidelines and offers a glimpse into the ways CarbonBetter can help you. Contact us today to learn more.
Staying Informed and Adapting to Change
As the world of making environmental marketing claims continues to evolve, staying informed on the latest trends, regulations, and consumer expectations is crucial. Regularly revisiting the FTC Green Guides and monitoring emerging greenwashing tactics will ensure your organization remains at the forefront of ethical marketing and communication. You can also click here to follow our newsletter on LinkedIn to stay informed on future updates. By adapting to change and maintaining a strong commitment to transparency and accuracy, you can foster long-lasting trust and loyalty among your target audience.
Conclusion
Navigating the complexities of sustainable marketing is a challenge that organizations must embrace to stay competitive in today's sustainability-driven world. The FTC Green Guides provide a valuable framework for ethical marketing and storytelling, while understanding emerging greenwashing tactics helps maintain credibility and transparency. Partnering with CarbonBetter can further support your sustainability journey, ensuring your organization remains ahead of the curve and aligned with best practices in environmental marketing.
As a leader in sustainability consulting services, CarbonBetter is here to help your organization navigate the intricacies of the FTC Green Guides while avoiding emerging greenwashing tactics. Our team of experts can assist you in implementing the guidelines, ensuring your marketing and storytelling efforts align with ethical and transparent practices. Reach out today to get started.
Following the FTC's Green Guides offers several benefits for businesses, such as ensuring transparent and accurate environmental marketing, fostering trust and loyalty among stakeholders, and protecting against potential legal risks and penalties. By adhering to the guidelines, your company can maintain credibility and compliance with environmental marketing standards. CarbonBetter can help your business navigate the Green Guides, implement them effectively, and develop an ethical marketing strategy. Reach out to us for assistance on your sustainability journey.
To stay informed about changes and updates to the FTC's Green Guides, regularly monitor the FTC website and sign up for their newsletters or alerts. Also, consider partnering with a sustainability consulting firm like CarbonBetter, which can help you stay current on the latest trends, regulations, and consumer expectations in sustainability marketing. Click here to follow our newsletter on LinkedIn.
CarbonBetter assists businesses in understanding and implementing the FTC's Green Guides through expert guidance, ensuring that your organization's marketing and storytelling efforts align with ethical and transparent practices. Our team of experts can help you navigate the intricacies of the Green Guides, identify potential areas of improvement, and develop a tailored marketing strategy that adheres to the guidelines. Contact us to learn more about how CarbonBetter can support your sustainability journey.
While the FTC's Green Guides provide a general framework for environmental marketing claims, certain industries may have additional or more specific guidelines. CarbonBetter can help you identify and understand any industry-specific considerations, ensuring that your organization stays compliant and follows best practices in environmental marketing. Reach out to our team for tailored guidance based on your industry.
If you suspect competitors are engaging in greenwashing, it is essential to stay informed about the FTC's Green Guides and maintain your organization's commitment to transparent and accurate environmental marketing. By following the guidelines, you can differentiate your brand from competitors and build trust with your target audience. CarbonBetter can support you in this process by helping you develop and maintain an ethical marketing strategy that aligns with the Green Guides. Contact us to ensure your organization stands out as a leader in sustainability marketing.
About the Author
Nicole Sullivan leads CarbonBetter’s climate practice, helping organizations measure, reduce, offset, and report on environmental impacts, including carbon emissions, water, and waste.
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