Dec 24 2010
In response to the Federal Trade Commission's (FTC) request for comments, the Glass Packaging Institute (GPI) has filed its comments in response to the FTC's proposed changes to its "Green Guides."
On December 10, the Glass Packaging Institute, which represents North American glass container manufacturers, filed its comments regarding the revised Green Guides.
The Green Guides were first issued in 1992 to help marketers ensure that the claims they are making are true and substantiated. The Guides were revised in 1996 and 1998. The guidance they provide includes: 1) general principles that apply to all environmental marketing claims; 2) how consumers are likely to interpret particular claims and how marketers can substantiate these claims; and 3) how marketers can qualify their claims to avoid deceiving consumers.
The proposed revisions include changes designed to strengthen the FTC's guidance on those marketing claims that are already addressed in the current Guides as well as to provide new guidance on marketing claims that were not common when the Guides were last reviewed. The proposed changes were developed using information collected from three public workshops, public comments, and a study of how consumers understand certain environmental claims.
"Our industry agrees with many of the changes proposed by the FTC," said Joseph J. Cattaneo, President of the Glass Packaging Institute. "These include the continued need for the guides in providing guidance to the packaging industry, setting a clear threshold of how much recyclable content can be included in a product for it to be considered 'recycled' and factoring in the amount of time it takes for material to breakdown in order to claim it is 'degradable'."
"Conversely, we think it is essential that the Green Guides clarify the difference between what is 'recyclable' and what is 'downcycled,'," added Cattaneo. "Many products that claim to be recyclable can't be recycled back into their original form, but are only downcycled into products that will eventually end up in a landfill. Glass packaging, by contrast, can be recycled endlessly back into glass packaging; its original form. Most other packaging materials cannot."
GPI also urged the FTC to ensure in its final guides that a truthful claim, such as that glass is "endlessly recyclable," can continue to be made. In addition, GPI urged the FTC ensure that claims that a product is "free of" a substance of consumer health or environmental concern, such as bisphenol A (BPA) can continue to be made for products, such as glass containers, that never have contained the substance to avoid inadvertently limiting provision of truthful and useful information to consumers.
The final Guides are expected to be released in late 2011.