Chelsea Burns, Content Editor
April 13, 2023
The Federal Trade Commision (FTC) first introduced the “Green Guides” in an attempt to create guidelines and boundaries for companies and their marketing claims around “green” language. In simple terms, the green guides help prevent brands from using misleading and greenwashing language on and in regards to their products. They also create boundaries for fair, legal competition—aka how companies can accurately say “we’re more eco-friendly than the other companies.”
The green guides were revised in 1996, 1998, and again in 2012. And, after 10 years, they’ll be updating the guides again this year and they’re looking for feedback (from anyone!) on what should be considered in these revisions. The guides provide guidance on everything from general environmental claims to renewable energy claims to carbon offset claims and you can share your thoughts on how they should be updated on any of them—or maybe even suggest new topics they should create guidelines around. At Blueland, we’re most concerned with their guidelines around degradability.
ICYMI, at the end of last year we petitioned the EPA to regulate the manufacturing and use of polyvinyl alcohol (PVA)—the plastic coating that all laundry and dish detergent pods are made with. From research we know that around 75% of PVA released from wastewater treatment plants is ending up in our waterways or soil. Yet, brands are still labeling their PVA-wrapped laundry pods and sheets as “biodegradable” – using words like “plastic-free” and “dissolving,” even though this plastic coating is not able to biodegrade in most water treatment plants in the U.S.
The current problem is that there simply isn’t a standard around what is considered “biodegradable” when it comes to products entering our waters. As it stands, the green guides only have guidelines around degradability claims for products that are being disposed of in the landfill. When it comes to products entering our landfills, the standard amount of time to degrade is one year. As a result, brands are labeling their products as biodegradable and not being held accountable to this misinformation. To prevent these false claims, we want the FTC to revise the Green Guides to provide guidance for products that are designed to degrade in wastewater treatment plants, not just in a landfill.
We’ll be submitting a formal comment on behalf of Blueland as a brand, but you can also leave a comment to voice your opinion and concern—you just have to do so by midnight EST on Monday, April 24th..
Here’s how to leave a comment on the Green Guides (in less than 30 seconds!):
Step 1: Go to the FTC site
Step 2: Insert your comment (Find an example below if you want to comment on biodegradability claims)
Step 3: Choose whether you want to share your name or leave your comment anonymously
Step 4: Submit!
The Commission should revise the Green Guides to provide guidance for degradable products that are designed to go down the drain. For these products, in order for a marketer to claim that the product is degradable or biodegradable, the product must be able to break down in the typical conditions of US WWTPs and degrade completely within the timeframe a product is in WWTPs.
For example, dishwasher and laundry detergent pods and sheets are designed to go down the drain and into wastewater treatment plants. These products are often marketed as “biodegradable”. However, these products are wrapped in or made with a thin layer of petroleum-based plastic called Polyvinyl Alcohol, also known as PVA and PVOH. PVA can biodegrade under specific conditions, however these conditions are rarely found in US WWTPs. Marketers can make biodegradability claims on PVA, that are misleading to consumers because while the product can biodegrade, it is unlikely to do so in current real-life scenarios.
Want to leave another comment?
Have something else you want to speak up about? Below are some guidelines the FTC shared about how to leave the most effective comment
- Read and understand the regulatory document you are commenting on
- Be concise but support your claims
- Base your justification on sound reasoning, scientific evidence, and/or how you will be impacted
- Address trade-offs and opposing views in your comment
- There is no minimum or maximum length for an effective comment
- The comment process is not a vote – one well supported comment is often more influential than a thousand form letters