Manufacturing Today - Winter 2012 - (Page 10)

COLUMN BY BY LYNN L. BERGESON Stay Truthful FTC originally issued the Green Guides in 1992. After years of public consultation, FTC issued draft Green Guides for comment in 2010, and states that it received “nearly 340 unique comments and more than 5,000 total comments.” FTC has modified sections on general environmental benefit, compostable, degradable, ozone, recyclable and recycled content. It has added new sections concerning carbon offsets, certifications and seals of approval, free-of claims, non-toxic claims, made-with-renewable-energy claims, and made-with-renewablematerials claims. FTC intends the Green Guides to help marketers ensure that the claims they make about the environmental attributes of their products are “truthful and non-deceptive.” As noted, while the Green Guides are merely administrative “interpretations” of law, and are not independently enforceable, they describe the types of environmental claims FTC may find deceptive under Section 5 of the FTC Act. State attorney generals often rely upon the guides to help enforce state consumer protection laws. E FFICIENCY E CONOMY Do Not Deceive the ftc releases revised green guides – seller beware ///////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////// Key Revised Sections General Environmental Benefit Claims – Marketers should not make broad, unqualified general environmental benefit claims like “green” or “ecofriendly.” Broad claims are difficult, if not impossible, to substantiate. Marketers should qualify general claims with specific environmental benefits. Qualifications for any claims should be clear, prominent and specific. Claiming “green, made with recycled content” may be deceptive if the environmental costs of using recycled content outweigh the environmental benefits of using it. To clarify this guidance, the final guides include new examples illustrating how marketers may make On Oct. 1, the Federal Trade Commission (FTC) released the longawaited revised Guides for the Use of Environmental Marketing Claims (Green Guides). The Green Guides are important for entities marketing products in the “green” space. While they are not directly enforceable in actions seeking to enforce false, deceptive and misleading environmental claims under Section 5 of the Federal Trade Commission Act (FTC Act), 15 U.S.C. Section 45(a), they are nonetheless very influential to the FTC and to state attorney generals’ offices that enforce state consumer protection laws and look to the guides for enforcement assistance. Entities making claims need to be fully aware of the significant marketing, business and legal implications of this document. 10 WINTER 2012

Table of Contents for the Digital Edition of Manufacturing Today - Winter 2012

Manufacturing Today - Winter 2012
Wauseon Machine
Applied Energy Solutions
Carter Control Systems
Global Technology Systems
Positech Corp.
Tampa Tank Inc./Florida Structural Steel
Carbide Products
Datacard Group
Fullerton Tool Co. Inc.
Honda of South Carolina
Fintube LLC
Sapa Extrusions North America
ACE Controls Inc.
Vendors Exchange International Inc.
EXEL North America
DJO Global
Capewell Components Co.
U.S. Sugar Corp.
Industrial Magnetics Inc.
Lakeside Plastics Ltd.
Norpak Handling Ltd.
Mid-State Machine Products
TenCate Protective Fabrics
The Dupps Co.
Western Manufacturing Ltd.
Wisconsin Plastics Inc.
Metrolina Greenhouses
LaSalle Bristol LP
Clarion Bathware
DAP Products Inc.
Honsa Ergonomic Technologies Inc.
Engineered Material Solutions LLC
Master Spas Inc.
Nypro Inc.
Kelly-Moore Paints
Palomar Technologies
U.S. Chemical & Plastics Inc.
Varflex Corporation
Votaw Precision Technologies
Watry Industries
Wigwam Mills
Banker Steel Co.
Last Page

Manufacturing Today - Winter 2012