The FTC's New Green Guides and the Perils of Compliance
The FTC's long overdue update of the Green Guides [PDF] will help protect consumers from vague green marketing claims. Among other proposed changes, summarized by the FTC here [PDF], the Guides will bar unqualified claims of "green" and "eco-friendly," further clarify how companies can use "compostable" and "recyclable," and require specifying what attributes of a product an eco-label applies to.
There are shortcomings in the proposed revisions. For example, they do not offer guidance on claims involving a product's life cycle or hidden tradeoffs (e.g., a product that saves consumers 50 gallons of water but consumes 5,000 to produce). They also don't address claims relating to Cradle to Cradle design or green chemistry, as Joel Makower points out.
Perhaps the biggest problem with the guides, however, is that they may merely yield greater compliance. Without a doubt, companies should comply with the new guidance, but merely doing so will not help them differentiate their products -- especially as green claims continue to proliferate.
Will consumers really prefer a product that is compostable in under a year vs. two years? In a few instances, maybe. Will understanding that the "Ecoproof" eco-label -- one of the almost 350 tracked by Ecolabel Index -- refers only to the textiles in a product make it leap off the shelves? I doubt it.
Instead of just focusing on complying with the revised guides, companies should take this as a wake-up call to redouble their efforts on product design and marketing that stays a step ahead of the minimum required.
Questions to consider include:
- Are we using other channels -- like environmental blogs and influencers -- to reach consumers beyond our product advertising and packaging?
- Have we baked environmental considerations into the product design process -- or do we primarily consider them in our marketing process?
- How can we design products that require no packaging -- not just create packaging with more recycled content?
Of course, the FTC shouldn't address these questions -- but leading companies should.