Guidance on Green Marketing Guidelines

February 9, 2011

Guidance on The Federal Trade Commission’s Green Guides

Established in 1914, the Federal Trade Commission’s (FTC) principle mission is the promotion of consumer protection. It is no surprise that they establish Green Guides for companies to use in evaluating their green marketing programs. The FTC's Green Guides look at all advertising from the consumer’s perspective. They examine the underlying messages that advertising actually conveys to customers, and explains how customers are likely to interpret environmental marketing claims so that marketers can avoid making false or misleading claims.

The FTC based their Green Guides on three criteria:
1) Substantiation: If a company is making assertions about a product’s green impact, those assertions must be based upon reliable evidence such as objective tests performed by professionals who are experts in the relevant field.

2) Specificity and clarity: If a company makes a marketing claim about their product, the claim should identify specifically what is green about the product. For example, suppose an advertiser claims that their wrappers are “environmentally friendly;” this does not meet the specificity and clarity test unless the environmental effect is made clearer. This company should therefore advertise that the wrapper is processed without the use of chlorine or other harmful substances.

3) No overstatements: If a company makes a marketing claim about their product, they should not overstate the benefits of the product. For example, if a pump spray is labeled “environmentally safe,” but most of the product’s active ingredients consist of volatile organic compounds (VOCs) that may cause smog in the ground-level ozone, the claim has overstated its environmental benefits and understated its negative effects.

Federal and state laws are in place to punish those who overstate their environmental benefits. In most cases, failure to comply would result in the recall or re-labeling of a product. The law also states that penalties can be as much as $10,000 per incident per day. However, the real detriment of misleading customers would not be the monetary fine or recall; the real detriment would be the loss of consumer confidence that could translate to large losses in market share.

Below is a list of questions that the Green Guides suggest ad agencies and internal marketers ask themselves about an ad campaign or product claim. Those reading these questions should answer them with the same sort of brutal honesty and skepticism that their everyday customers would possess.

Does it mislead with words?
Does it mislead with visuals or graphics?
Does it make a green claim that is vague or seemingly un-provable?
Does it overstate or exaggerate how green the product/service/company actually is?
Does it leave out or mask other important environmental information?
Companies should strive to be open and honest. Overstating environmental benefits of a product is wrong to do and undoubtedly harmful to a company in the long run. If you have questions or need an expert assessment of your advertising and/or green initiatives, please don’t hesitate to contact me at Often, companies are not being purposefully deceptive, they just don’t realize that they are overstating or wrongfully assuming environmental benefits.




Good info! Greenwashing is indeed pandemic. I always thought it'd be very helpful to include estimated amounts of CO2 emissions, embodied energy and that kind of info just like the info on a Nutrition Facts label...that'll help us make better decisions. E.g. a $10 t-shirt from Laos with 1000 kJ of embodied energy v. $15 t-shirt from NC with 400 kJ embodied energy (I made up those number, but you get the point).

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