Remarks from industry groups focused on such topics as uniformity of standards, using data to back policy and recognition of the ever-changing recycling landscape. | G0d4ather/Shutterstock

The Federal Trade Commission requested comments on its revisions to the Green Guides and got 850 responses, with many calling for a crackdown on deceptive claims and better definitions of key terms. 

The decade-old Guides for the Use of Environmental Marketing Claims, otherwise known as the Green Guides, cover recycling, compostability, ozone impacts, carbon offsets, the use of healthy ingredients, claims about general environmental benefits, manufacturing with renewable energy, and more. When it comes to recycling, they discuss when and how marketers should make claims about recyclability and recycled content. 

The Federal Trade Commission (FTC) is looking to update those guides and asked for public and stakeholder comments by April 24. Several large organizations submitted comments, including the Plastics Industry Association, the Association of Plastic Recyclers (APR) and The Recycling Partnership. 

Stakeholder feedback

The Plastics Industry Association encouraged “national common-sense standards to promote truth in advertising on all aspects of environmental marketing” and to clean up the growing patchwork of state laws. The Green Guides should offer guidance in a technologically and material-neutral manner, the group added. 

The Recycling Partnership focused on a “rigorous, data-driven approach to determine recyclability, combined with accurate, transparent recyclability claims on product labels” in its suggestions.

Recyclability should be based on accessibility to collection programs, effectiveness of sorting the item and sufficient end markets for it to be used in the production of new packaging or products. 

For APR, it’s important that the updates narrow in on recycled content claims to only allow PCR defined under the ISO definition and that they continue to use a calculator method on a per-product or annual weighted average, as opposed to mass balance, credit trading or other similar systems. (APR owns Resource Recycling, Inc.) 

“Consumers purchase a product with recycled content with the implied understanding there are recycled materials in that actual product, and claims must conform to that understanding,” APR’s comment noted. 

APR also encouraged the FTC to increase enforcement of deceptive or unqualified claims of recyclability and recycled content, maintain the current threshold of 60% consumer access for recyclability claims and update the Green Guides again within five years. 

AMP Robotics pointed out in its comment that “the recycling industry is fundamentally different today than it was in 2012 when the last revision of the Guides for the Use of Environmental Marketing Claims was released.” 

Specifically, the robotics and AI company said the guides should take into account how those technologies have been changing what can be accepted for recycling and the effects of extended producer responsibility laws for packaging.

Comments submitted collectively by The Last Beach Cleanup, Just Zero, Plastic Pollution Coalition, Beyond Plastics, Center for Biological Diversity and Greenpeace USA called on the FTC to codify the Green Guides into law, incorporate provisions of California’s Truth in Labeling law, ban “store drop-off” labels unless the company can demonstrate that the program recycles at least 75% of the covered materials and define recycled content as “actual physical content from materials that have passed through the hands of individual consumers,” not mass balance.

A version of this story appeared in Plastics Recycling Update on Apr. 25.

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