Green and Environmental Labeling

Cookware Manufacturers Association

The U.S. Federal Trade Commission has Guides for the Use of Environmental Marketing Claims.

wildgarlicThe U.S. Federal Trade Commission’s Guides for the Use of Environmental Marketing Claims (Green Guides) are the centerpiece of the agency’s environmental marketing efforts. The Green Guides help marketers avoid making false or misleading green claims by explaining how consumers understand commonly used terms, such as “biodegradable” and “recyclable,” and by describing the basic elements needed to substantiate those claims. The complete text of the guide can be found here.

Here are some highlights and particular factors to consider when labeling cookware and bakeware with environmental claims.

Claims should be substantiated. As with all advertising claims, the producer should substantiate thoroughly any claims made for the product. This substantiation should be accomplished before the product is placed into the marketplace, not after.

An environmental claim should not overstate the environmental attribute of benefit expressly or by implication. Marketers should avoid the implication of significant environmental benefit if in fact the benefit is negligible. For example, a packaged labeled 50% more recycled content than before when the increased recycled content of the product increased from 2 percent to 3 percent would create a false impression.

Comparative claims should be presented in a manner that makes the basis for the comparison clear to avoid consumer deception. For example, a product claiming that “less energy used to produce this product” should in fact be substantiated and qualified. Less energy than what? The previous product? A competitive product?

It is deceptive to misrepresent, directly or by implication that a product, package or service offers a general environmental benefit. Every claim must be substantiated. For example, a brand such as “Eco-Safe” would be deceptive if it leads consumers to believe that the product has environmental benefits when, in fact, there is no substantiation as to any benefits the product has for the environment. Examples of other potentially problematic statements would include: “environmentally safe,” “environmentally friendly,” “non-toxic,” or “earth smart”.