According to a recent survey from consulting firm Kearny, around 40% of consumers factor in sustainability when purchasing food. With growing consumer interest in foods and other productsthat align with their values, transparency in marketing is becoming increasingly important. The Federal Trade Commission (FTC) developed its Guides for the Use of Environmental Marketing Claims (or “Green Guides”) to serve as a set of guidelines for businesses to ensure that their environmental marketing claims are truthful and not misleading to consumers. The Green Guides provide guidance on how to avoid making false or unsubstantiated environmental claims, also known as “greenwashing,” which can harm both consumers and the environment.

The Green Guides cover a wide range of environmental claims, including statements about the use of renewable energy, recycled content, biodegradability, and carbon offsets. They also provide guidance on how to use specific terms, such as “compostable” and “recyclable,” and when it is appropriate to use certain certifications. These guides are not laws or regulations but are intended to provide guidance for businesses to comply with the FTC Act, which prohibits unfair or deceptive advertising.

These guides are updated around every 10 years, with the last update being made in 2021. In response to the Federal Trade Commission’s (FTC) request for input on Green Guides, PBFA submitted a comment on behalf of our members, which can be found here.

PBFA members support “sustainable food production that ‘meet[s] the needs of present and future generations, while ensuring profitability, environmental health, and social and economic equity.” In pursuit of those goals, our comment discussed green packaging and practices surrounding claims of recyclability and compostability.

Given the fact that only around 5-10% of plastic is actually recycled in the U.S., there is definite room for improvement. More to the point, the Green Guides can do more to empower consumers who want to participate in practices such as recycling and composting by ensuring they receive the proper information on how to do so most effectively. PBFA is committed to sustainability and through this comment, we urge the FTC to ensure the Green Guides reflect a similar commitment.