FTC Green Guides – What the Proposed Changes Mean for Marketers

On Wednesday, after more than two years of long-anticipated review, the Federal Trade Commission (FTC) released proposed changes to its Guides for the Use of Environmental Marketing Claims (aka Green Guides). The issues addressed in the two-page synopsis of changes are summed up simply by FTC Chairman, Jon Leibowitz, who said, “…what companies think green claims mean and what consumers really understand are sometimes two different things.”

The proposed changes aim to mitigate consumer confusion by requiring companies to provide factual evidence to back up environmental claims. During a media briefing on Wednesday, the commissioners noted they anticipate enforcement of environmental marketing to decline (there were seven enforcement actions taken in 2009), believing many companies want to comply and are seeking more guidance.

The FTC’s rules may change over time, but Cone’s guiding principles for effective environmental marketing stay the same:

Be precise. Make specific claims that provide quantitative impacts.

  • Americans say quantifying the actual environmental impact of a product or service is influential in their purchasing decisions. In addition, the more precise an environmental claim, the more convincing Americans believe it to be.

Be relevant. Demonstrate a clear connection between the product or service and the environment.

  • Americans say providing a clear connection between the product/service and the environmental issue (i.e., a hybrid car and lower emissions) influences their purchasing decisions.

Be a resource. Provide additional information for consumers in a place where they want it.

  • A website is great, but based on the FTC’s latest comments, be sure to also provide proof at point-of-sale.

Be consistent. Don’t let marketing images send a signal that contradicts the carefully chosen words and facts you use.

  • For example, showing an automobile parked in a virgin forest may be seen as insensitive, while a product growing out of a tree may be seen as exaggeration.

Be realistic. Communications that include some sense of context, as well as a “work in progress” tone, will be more credible and less subject to criticism.

Cone’s Chief Reputation Officer, Mike Lawrence, provides his initial reactions to the FTC Green Guides proposal in a video response and post on our blog. What is your reaction to the proposed Green Guides revisions? Share your thoughts by voting in our latest What Do You Stand For? poll. 


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