FTC Panels Discuss The Green Guides, Recyclability, And Consumer Perception
In December, the FTC announced that it would seek public comment on a revision of its Environmental Marketing Claims Guidelines, also known as the "Green Guidelines," which were last updated in 2012. The guides give you advice on what to do. 15 USC 45 of the Federal Trade Commission Act prohibits “unfair or deceptive trade practices or practices ”. ''
The guidelines include general environmental requirements and some specific requirements. Areas of concern for plastics manufacturers include: On May 23 , the FTC hosted a workshop to discuss recycling marketing issues.
The commonly used symbol for PS is theoretically and technically not a practically or economically recyclable material. Many expressed concern that including the target symbol would mislead consumers into believing it could be reused.
Photo: public domain
James Kohm, deputy director of the FTC's Office of Consumer Protection, opened the event by noting that the FTC's role is not to make environmental guidelines, but to prevent misleading marketing claims. “The Green Guidelines are an interpretation of FTC Section 5, which prohibits misleading advertising. Misrepresentation claims are not about the meaning of the claim, but about how consumers reasonably interpret the claim,” says Kohm.
Marketing Requirements and Processing Measures
Panelists Hampton Newsom and Julia Solomon Ensor, attorneys for the FTC, shared their thoughts on the current state of recycling and current marketing needs.
Public enthusiasm for recycling remains high, fueled by a broader interest in sustainability. "People are genuinely trying to help the environment and want to buy sustainable products that are good for the earth and are willing to pay more," said Bonnie Patton, CEO of Truth in Advertising. dr Kunta Warren, associate director of sustainability policy at Consumer Reports, says that 70% of consumers recycle at least frequently. "We're in a good position now because we don't have to convince consumers to recycle because the survey shows they already want to," Warren said.
This trend has encouraged brands to focus their marketing efforts on this buzz. Retailers may or may not submit claims for acceptable recycling. The marketing claim "local check" is an example of a simple qualification, while an unqualified claim simply says "can be reused".
Green guidelines currently recommend marketers not to make improper recycling claims when 60% of consumers are unable to recycle the product.
According to the CEO of the Waste and Recycling Association, members of the organization report contamination rates of up to 20%, which stems from a misunderstanding of what recycling programs allow. "We believe that labeling has a major impact on this pollution and awareness," says Germain. Germain explains that some of the biggest problems with MRFs are caused by plastic wraps, which damage the machine and often lead to shutdowns. And lithium batteries, which are dramatically increasing the number of fires at recycling plants.
The plastic debate is an area of great disparities between the environment and the potential for misinterpretation. "98 percent of our clutter is plastic," said Adam Redel, director of the Arlington County Office of Environmental Management.
Inventories are generally strong when associated end markets are strong, such as PET bottles, but there are differences in dealing with low-grade materials. Arlington County, for example, records tar codes 3, 4, 6, and 7, although Reed doubts these materials are recycled.
According to Keith Bailey, policy director of the Association of Plastic Recyclers, 40 million Americans don't have proper garbage disposal. But that can change. "The pressure to improve recycling, and plastics recycling in particular, has never been greater," Bailey said.
Raising consumer awareness of recycling requirements
"Our research shows that people's opinions and how confident they are in interpreting claims has a direct impact on whether or not they recycle," said Sarah Derman, director of innovation at the Recycle Partnership. According to Dearman, intelligent quality requirements meet the need for transparency while maintaining an ever-evolving approach to reusable packaging.
Panelists were asked to think about what poor recycling requirements mean for customers. "When people see a recycling symbol or message on packaging, they expect something new to come out of it," says Derman, whose research shows recycling is over.
Karen Hagerman, director of GreenBlue's How2 recycling program, described the results of the research, from theoretical recycling to 100 percent recycling. “There was a strong consensus in the category that materials are often, but not always, recycled. We find this encouraging as it fits the definition of the Green Guidelines,” says Hagerman.
Do the back arrows represent the recycling requirement?
Several members noted that the current implementation of the district identifier code was confusing. Area codes are usually surrounded by an arrow symbol. "Hunting darts means using something other than plastic," explains Anne Germain. According to Peter Blair, Director of Policy at Just Zero, only 8% of respondents understand that the Resin Code is not a guarantee of recycling.
In 2013, the standard in ASTM 2011 changed the use of resin identification codes, replacing the arrows with a filled triangle. However, adopting the new design was a challenge. Many state laws require the use of a rear turn signal. California passed a new law requiring a disclaimer to appear on plastic containers that state regulations do not allow them to be "recycled."
The future of green guidelines
Panelists were asked to consider how the FTC should address fraudulent reuse claims under its current mandate. The answers are varied. "It is not the consumer's responsibility to identify green claims," said Dr. Kunta Warren. "We need the FTC to develop clear guidelines that businesses must follow but consumers can use."
Raisa Lerner, Assistant Attorney General for the State of California, cited recent cases where courts treated processing requirements merely as technical processing capabilities. “Maybe we're talking about the end user and not just throwing it in the trash, but it can be clear through and through because it's about consumer protection; he is the beginning of the process.”
Patrick Krieger, vice president for sustainability at the German Plastics Industry Association, points out the difference between recycling and proving that something is recycled. "The word recyclable means, and especially when we use it qualified, that you have the capacity (not recycled)," explains Krieger, "you have to be able to make a finished product." But it's different from "should." ' because there are many economic factors that are beyond the producers' control.
Peter DePasquale, Vice President of Government Affairs at Dr. Pepper, Keurig said they were looking for a reusable design. "We have MRFs and recyclers saying we need products and packaging a certain way to have an end market and I think that should be part of the analysis if reuse design is to follow known design guidelines."
More ways to listen
The FTC invites further public comment through June 13, 2023. See Regulation.gov for instructions on how to submit comments. The EPA is also soliciting public opinion on a national plastic pollution strategy. Comments must be submitted by June 16, 2023.
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