Environmental issues and concerns, and how brands respond to and mitigate them, have never been more important to consumers. Businesses, including those in the promotional products industry, are responding with processes and products featuring a whole range of environmentally friendly measures. These range from sustainably sourced and recycled goods, carbon reductions and offsetting, to clean energy and water, and much more.

Accurately communicating these accomplishments to customers represents its own challenges and pitfalls.

The Green Guides

To help marketers avoid making environmental marketing claims that are unfair or deceptive, the Federal Trade Commission introduced its Green Guides in 1992. Sometimes what companies think their green claims mean and what consumers really understand are two different things, and the FTC’s Green Guides are designed to help marketers avoid making environmental claims that mislead consumers.

Guidance includes:

  • General principles that apply to all environmental marketing claims.
  • How consumers are likely to interpret particular claims and how marketers can substantiate these claims.
  • How marketers can qualify their claims to avoid deceiving consumers.

The Green Guides have been revised three times since their 1992 introduction, most recently in 2012, as technology and the marketplace evolve. This month, the FTC is meeting to finalize a new update to the Green Guides, informed by a public comment period that ended in April and a slew of greenwashing-related lawsuits.

  • “Greenwashing” – sometimes referred also referred to as a “green sheen” – is a marketing practice that seeks to deceptively frame an organization or business’s products, services and policies as environmentally friendly.
  • The term was coined in the mid-1980s in reference to the hotel industry practice of promoting towel reuse to “save the environment” that was less about reducing energy use and more about cutting laundry costs.

A new trend uncovered during the FTC’s public comment period is “greenhushing.” This is the practice of under-reporting corporate sustainability efforts in order to avoid claims of greenwashing and risking lawsuits.

  • Greenhushing represents its own challenge to environmental responsibility, as the lack of information clouds products’ actual environmental impact, preventing consumers from making informed decisions.

Green Guide Revisions

On April 24, the FTC’s public comment period on the proposed changes to the Green Guides came to a close. Initiated in December 2022, the comment process sought public responses on the Green Guides in general, as well as specific issues that will potentially make their way into the revised document.

Certain specific issues that have generated increased attention and interest over the last several years. These issues under examination in the review process include:

  • Carbon offsets and climate change. The Guides currently include guidance relating to carbon offsets, and the FTC may revise this section addressing other types of advertising claims related to carbon offsets and/or climate change. This would include research regarding consumer perception of climate change-related claims such as “net zero,” “carbon neutral,” “low carbon” or “carbon negative,” etc.
  • The term “Recyclable” in marketing. The FTC may change the current threshold that guides marketers on when they can make unqualified recyclable claims and address “recyclable” claims for products that are collected by recycling programs but not ultimately recycled.
  • The term “Recycled Content.” The Green Guides may provide additional guidance on whether unqualified claims about recycled content – particularly claims related to “pre-consumer” and “post industrial” content – are widely understood by consumers and whether alternative methods of substantiating recycled content claims may be appropriate.
  • Several other common terms used in marketing and communicating environmentally-friendly programs and products may come under additional FTC scrutiny, as the FTC sought public comment on the need for guidance regarding claims such as “compostable,” “degradable,” ozone-friendly,” “organic” and “sustainable,” as well as claims regarding energy use and energy efficiency.

The FTC is hosting a workshop, “Talking Trash at the FTC: Recyclable Claims and the Green Guides,” on May 26 examining consumers’ perceptions of recycling and recycling practices.

Promo In Green

The promotional products industry is making significant strides in ensuring its merchandise is environmentally responsible and meets clients’ sustainability needs. Several promo companies are leading the way with sustainable production and operations, clear and detailed communication of their practices and accomplishments, and tools to make environmentally responsible products easier to source.

Some recent examples of the industry’s accomplishments include:

  • In search of green energy and controlling electricity costs, several industry companies have invested in solar power at their facilities. Geiger’s array, for example, is the largest privately-owned solar panel system in the state of Maine.
  • Polyconcept North America’s ProudPath program recently marked its first year. The supplier’s platform gives distributors a turnkey platform to meet their clients’ environmental and social responsibility goals.
  • Next Level Apparel is transitioning its entire product line of polyester blended fabrics to recycled polyester, and to help clients track their sustainability efforts, Storm Creek is adding upcycled bottle counts to its invoices and shipping information.

PPAI’s Product Responsibility Summit, to be held October 8-10 in Washington, D.C, will focus on the business implications of a wide range of product compliance issues, including sustainability. Click here for more information and to register.