WASHINGTON, D.C. — The Center for Climate Integrity (CCI) yesterday submitted recommendations for how the Federal Trade Commission can better protect consumers against new forms of deceptive advertising that mislead the public about corporations’ contributions to the climate and plastic pollution crises, such as the false promotion of plastics as recyclable, and the increased but unregulated use of terms such as “net zero.” CCI submitted its comments as the FTC is soliciting public feedback for how to update the Commission’s Green Guides, which provide guidance for environmental claims in marketing and advertising.
“Since the Commission last updated the Green Guides, environmental marketing has changed dramatically,” CCI wrote. “With the world now facing the consequences of both a climate crisis and plastic waste crisis, a growing number of U.S. consumers are demanding environmentally-conscious business practices and products. A business or industry branded as ‘green’ or ‘sustainable’ is no longer a novelty, it is a necessity to meet the needs of consumers who are calling for change. Continued and further guidance is needed to set clear standards and address new means of deception and disinformation in environmental marketing.”
CCI identified the following areas where stronger guidance and regulations from the FTC could help protect consumers and hold corporations accountable:
- Paltering: “the use of truthful statements that create an overall false or misleading impression.”
- Reputation Advertising: “a new form of greenwashing that uses misleading and deceptive environmental claims … to increase sales by capitalizing on consumers’ desire to conduct business with environmentally conscious or sustainable businesses.”
- Deceptive claims about the recyclability of plastics products: “The plastic waste crisis is being perpetuated by unfair and deceptive advertising claims about plastic recycling. Consumers want to make environmentally-conscious choices, and thanks to decades of industry advertising, they are apt to believe that recycling is the solution to the plastic waste crisis. By promoting plastic products as recyclable, marketers assuage consumer guilt about contributing to the growing plastic crisis. Yet, plastic is overwhelmingly not recyclable, and marketers know – and have known – this for decades.”
- “Advanced recycling” and “circular economy” claims: “Even though the plastics industry has known about the technical and economic limitations of plastic recycling for decades, they have misled consumers into believing plastic is more recyclable than it is. Consumers have been misled by deceptive labeling, including the ‘chasing arrows’ symbol, and are now being misled that so-called new technologies in ‘advanced recycling’ will bring plastics into the ‘circular economy.’ Such claims are unfounded. The Green Guides must be modified to address consumer deception concerning plastic recycling, specifically deceptive labeling on plastic products and emerging claims about advanced recycling. They must also establish appropriate standards for circular economy claims.”
- “Net Zero” claims: “More than 700 of the world’s largest companies have claimed ‘net zero’ targets, yet there is no established interpretation for this claim. The Green Guides must establish a standard definition for ‘net zero’ that is comprehensive in scope and credible in application. Corporate ‘net zero’ claims must cover all direct and indirect greenhouse gas emissions from across the company’s entire portfolio and value chain, and they must distinguish between emission reductions, post-emission compensation, and emission divestments. Further, the Green Guides must ensure that companies cannot make or imply long-term ‘net zero’ claims that are unsubstantiated by company plans, even if such commitments are qualified as ‘ambitions’ or ‘goals.’”
Read CCI’s full comments here.