FTC Green Guides & Other Bioplastic / Environmental Marketing Claims Guidance

Posted on 10/31/2012 8:53:19 AM By Jeff Timm

Wow!  After years of waiting, and if you are a consumer having been confronted with many misleading inaccurate or false environmental marketing claims on all sorts of consumer products and packaging, the Federal Trade Commission (FTC) issued their revised Green Guides on October 1, 2012.  Not only did the Green Guides issue in October, a variety of other environmental attribute guidelines from a number of other noteworthy entities around the world issued within the last two months.

First, the Green Guides.  The last update occurred in 1998.  The new updates cover the existing Guides as well as new sections on the use of carbon offsets, ‘green’ certifications and seals, free-of claims, non-toxic claims and renewable energy and renewable materials claims.  Also covered are all the confusing terms -- degradable, compostable, biodegradable, recycled, recyclable, less waste, non-toxic, VOC–free, earth-smart, eco-friendly, renewable and of course the word ‘green’ itself.  Another really informative aside from the actual Guides are the 340 individual public comments from corporations, trade associations, individuals and other parties.  These comments make fascinating reading and many times clearly state the corporate or industry position on environmental issues and broader sustainability attributes and agendas of the respective companies, trade associations, etc.

Other announcements in the last two months have come from the European Bioplastics Association, the European Union (EU), the PET Resin Association (PETRA) and the Association of Post Consumer Recyclers (APR).  European Bioplastics on September 10, 2012 published its Environmental Communications Guide for Bioplastics.  This guide sticks closely to applications made from bioplastics only.  It is not as broad as the Green Guides, but serves as an excellent companion piece to the FTC document.

A coalition under the auspices of the EU funded a research project -- Knowledge Based Bio-based Products’ Pre-Standardization (KBBPPS) and will soon conduct pre-standardization research, test methods, into bio-based products.  The project is being led by the Netherlands Standardization Institute.  The objective is to provide the European and global market with standards on biomass content and biodegradability on plastics as well as other product categories that are applicable in ‘real world’ situations.  The results of the project will be woven into European standards once realized.

Lastly, the other piece of recent ‘guideline’ news came this month when the PET Resin Association announced its Recyclability and Innovation Model followed on by the Association of Post Consumer Recyclers rebuttal of the model.  Although it is a stretch to call these guidelines, they are really a testing method; they do impact the discussion as they affect the reliability and make-up of the PET recycle reclaim stream.  The PETRA model provides voluntary criteria for testing, evaluating and ensuring the recyclability of newly developed PET resins (PETRA calls these ‘innovation’ resins) that are used in manufacturing PET bottles and containers.  The rationale behind the new guideline is the belief by PETRA that the current APR PET recycle reclaim stream standards do not sufficiently address a protocol for including newer PET grade variations in terms of their likely market presence and subsequent impact on the quality of reclaimed PET.  The APR test procedure specifies two tests of 25% and 50% respectively of new PET grades be present in control reclaim material (water-grade and CSD-grade industry control resins that are representative of the North American virgin PET supply) to test for recycle feed compatibility and quality.  The intent is to measure the impact of these new grades in the reclaim at the two stated levels.  PETRA believes these percent levels are too high and not realistic in the recycle process and reclaim feeds faced by most recyclers.  They suggest levels of 2% and 10% be added to the two existing levels to reflect what they feel is a more true representation of what actually occurs in the recycle reclaim feed seen by most recyclers.  APR states that they have performed testing in the past with low levels of different new resins and found negative performance issues based on common PET industry specifications, standards consisting of a set of requirements, such as IV, filterability, melt point, solid state polymerization and color/haze plaque testing that can affect the whole PET recycle industry.  Thus APR is not endorsing the new PETRA model.

This tiff between PETRA and APR is unfortunate.  APR has been in disagreements before with other associations in the PET recycle arena.  Back in July and August the APR and NAPCOR fought it out in the press over a new ‘recycle without the numbers’ program sponsored by APR.  As I wrote in my Packaging Blog on September 4 “the controversy that these guidelines have caused creates another black-eye for the plastics industry.  At a time when everyone wants to blame the plastic industry for much of what is wrong with the environment one ‘talking point’ on plastic recycling should be the objective.  Instead we have multiple sources posturing to distance themselves from these ‘education without the numbers’ guidelines.”  As one can easily see this quote applies to this recent spat as well...too bad!

In conclusion, it is very encouraging that environmental attributes are being clarified and quantified by the FTC and others.  It is now up to the whole plastics, adhesives and packaging industry value chain to apply these guides.  More importantly, industry needs to translate the attributes to benefits they deliver to consumers.  Study after study indicates consumers’ feel strongly about environmental attributes.  But consumers don’t want misleading or untrue claims.  For example they want to know how recycling benefits them or the planet.  They want fact driven instruction on how to compost or fulfill some other environmental claim.  In other words they want environmental attribute claims they can relate to and engage let’s give it to them!


While we are talking about guidelines and standards it is important to note The Adhesive and Sealant Council Inc. recently announced that it has collaborated with Europe-based FEICA and China-based CATIA to release the 2012 ASC-CATIA-FEICA Adhesives and Sealants Classification Manual.
The manual reportedly provides a common set of market definitions and product categories that can be used to represent the adhesive and sealant industry worldwide. It is the first time that China, Europe and North America have harmonized the classification manual. In 2008, the ASC and FEICA harmonized their respective manuals.

“For the first time, the three major adhesives and sealants markets–China, Europe and North America–share a common language when it comes to defining the marketplace for adhesives and sealants,” said Matthew E. Croson, president of the ASC.  “The project began in September 2011 in a meeting with Bernard Ghyoot of FEICA and Michael Yang of CATIA when we were together in Guangzhou, China, and culminated in the effort being announced at the World Adhesives Conference recently held in Paris, France. The adhesives and sealants market travels on a global passport, and now all of the major markets speak the same language when it comes to defining the industry.”

NOTE:  The views and opinions expressed in the Packaging Blog are solely those of the blog author and do not necessarily reflect the views and opinions of the Adhesive & Sealant Council (ASC).

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