A picture is worth a thousand words. There’s a reason this is a cliché - we’ve all heard it before. Why then, do we often overlook this simple truth when it comes to environmental marketing and advertising? Polar bears and virgin forests are the visual equivalents of “green” and “eco-friendly,” yet as marketers we spend the majority of our time crafting accurate and precise written claims only to have them undermined by misleading visual cues.
The Federal Trade Commission is also guilty of this oversight, which is why Cone filed comment today as part of the Commission’s two-year review of the Guides for the Use of Environmental Marketing Claims (“Green Guides”). Despite the Commission’s rigorous review of the outdated Guides and over 200 pages of detailed analysis in the full report, it provided little guidance for marketers on how to correctly use imagery to convey credible environmental claims. (Indirect references seemed to include: “Through examples, the Guides also advise marketers that qualifications should be sufficiently ‘clear and prominent’ to convey the idea that the claim refers only to limited environmental benefits and that ‘no other deceptive implications are created by the context.’” Emphasis is ours.)
We do not believe this will be sufficient to end misleading communications by companies whose hyperbolic imagery and stated (or implied) claims lead to different conclusions. We urged the Commission to offer examples, real or hypothetical, that showcase the juxtaposition of misleading imagery with qualified or unqualified claims. Companies and consumers will benefit from the guidance.
It is not surprising that marketers often opt for the utopian in their environmental communications – marketing and advertising are aspirational by nature. But faced with the environmental realities of most products and services, truthful is really what consumers deserve.