Life Cycle Thinking blog is moving.
I will continue to provide commentary about TSCA, REACH, product stewardship, sustainability, environmental marketing claims and more as part of the redesigned EHS Strategies, Inc. website.
Posted in Environmental Marketing Claims, Product Stewardship, REACH, Sustainability, TSCA, TSCA Reform, tagged EHS Strategies Inc., Environmental Marketing Claims, life cycle thinking, Product Stewardship, REACH, Sustainability, TSCA on March 22, 2013 | Leave a Comment »
There are more examples and terms explained, but it still comes down to two basic principles:
1. Be technically accurate
2. Do not mislead
That last one is the challenge. You have to follow public and customer understanding of what they think terms mean and cool it with the “green” art. We’ll see if FTC steps up enforcement.
Interestingly, GreenBiz posted a couple articles Nov 19. Getting the word out on how to more careful with claims is good.
Interesting article on LEED certification: http://www.usatoday.com/story/news/nation/2012/10/24/green-building-leed-certification/1650517/
It’s not so easy to come up with a green standard – lots of competing goals and caveats to encourage enough buy-in to get organizations to use the standard. Unfortunately, many government organizations make assumptions about LEED without looking at the shortcomings because it’s simple to glom onto. Like every other system out there, lots of people will game it. How do you set up enough post-certification validation checks without dragging the whole system down? LEED has caused movement in the right direction overall, but maybe not much.
It’s not simple being “green.” Or telling if something is really “green.” FTC tries to offer guidance, but there’s still plenty of room for mischief.
In concert with comments I submitted against general environmental claims, FTC says:
Marketers should not make broad, unqualified general environmental benefit claims like ‘green’ or ‘eco-friendly.’ Broad claims are difficult to substantiate, if not impossible.
Marketers should qualify general claims with specific environmental benefits.
Qualifications for any claim should be clear, prominent, and specific.
- When a marketer qualifies a general claim with a specific benefit, consumers understand the benefit to be significant. As a result, marketers shouldn’t highlight small or unimportant benefits.
- If a qualified general claim conveys that a product has an overall environmental benefit because of a specific attribute, marketers should analyze the trade-offs resulting from the attribute to prove the claim.
And Hooray! they didn’t try to deal with “sustainable.”
I like FTC’s approach to logos and seals, too:
Marketers shouldn’t use environmental certifications or seals that don’t clearly convey the basis for the certification, because the seals or certifications are likely to convey general environmental benefits.
Not so happy they left the ability to say “free of” – which I think is often an unsubstantiated allegation of harm caused by the not-there chemical, rather than a simple statement that it doesn’t contain a chemical.
The 300 page background document actually referenced my comments 38 times! Nice to be heard.
Still lots of room for interpretation, but an improvement. Now if they’ll only enforce the Guides.
Contact EHS Strategies, Inc. for help keeping your claims compliant.
The new NSF/ANSI 355 – 2011 standard on Greener Chemicals and Processes Information has been released after a lot of work by a passionate joint committee (including yours truly) from industry, ACS Green Chemistry Institute (the sponsor), EPA, academia, NGOs and NSF.
This is an attempt to provide a vehicle for standardized information for business to business communication about factors that describe “greenness” presented in a way to allow each customer to weight those factors that mean the most for its business. It’s meant to stimulate dialog and greener choices, rather than to generate a “scorecard” per se.
We also think this goes beyond cataloging hazardous properties of chemicals to describe important aspects of the chemical manufacturing process. This is focused on the first manufacturing stage of the life cycle and is meant to be used by chemical manufacturers and their customers. Working up the full life cycle will be the next steps.
EHS Strategies, Inc. can help you explore the use of the standard, but does not provide 3rd party certification.
Posted in Environmental Marketing Claims, Events and Articles, Product Stewardship, REACH, TSCA, tagged EHS Strategies Inc., Environmental Marketing Claims, life cycle thinking, Product Stewardship, REACH, Sustainability, TSCA on July 13, 2011 | Leave a Comment »
Current and recent events and articles:
January 22, 2013 Once again I’m teaching “Regulations and Corporate Environmental Management” at the University of Minnesota Spring Smester (ESPM 3602/5602 MGMT 3602). My goal is to expose students to the power and frustration of public rulemaking in the environmental arena and how corporations cope.
January 18, 2013, article in MA Insider: “Greening Your Supply Chain.”
November 15 and 17, 2011 Dept of Commerce, US Commercial Service webinar “EU REACH – What You Should be Doing.” I spoke on the 17th on “Protecting Your Supply Chain.”
August 17 and June 15, 2011 Minnesota Trade Office Updates of EU WEEE and RoHS Recasts and REACH Regulation I focus on REACH article requirements.
March 21, 2011 PDMA (Product Development and Management Association) talk on “Opportunities and Challenges: Making it ‘GREEN‘”
March 29, 2011 Filter Manufacturers Council presentation in Chicago on chemical regulatory and customer pressures.
April 14, 2011 TSCA Overview for the Minnesota chapter of Certified Hazardous Materials Managers training class.
I spoke at the I spoke at the Minnesota Green Chemistry Forum’s “Adding Value Through Green Chemistry” conference January 7, 2011, on the topic of environmental marketing claims opportunities and challenges for companies.
Nice summary of whether there is really anything behind the surveys on all the consumer demand for “green” products by Joel Makower http://bit.ly/eYG9Ef Essentially, he says that consumers say they want green, don’t really know what “green” (or “sustainable”) means and won’t pay more because they either don’t trust companies and/or are buying on price and performance. Except for a few diehards who are true believers and/or want everyone to view them as green (a status thing).
I also recently heard Dr. David Berube, Professor in Science & Technology Communication at North Carolina State University, describe how you can conduct surveys that “prime” respondents to answer however you want. He said that most opinion surveys give worthless data. (He spoke on consumer perception of nanotechnology. Is the question set up with a “good” or “bad” or no definition? The majority of people have no clue what “nano” means. Go 1.17 hr into an older video here using Username: sra Password: sra011910)
So what should a company do? Be as clear as possible about what you’ve done with your product or process and be able to prove it. Better, talk about what you are continuing to do to improve the product’s environmental footprint. Most importantly, understand what motivates your customers and where they get their information.
USDA has published its final rule on a voluntary product certification and labeling program for “biopreferred products” – bio-based materials containing products (like NatureWorks corn-based polylactic acid polymers). See rule and guidance here. The program is set for launch Feb 21, 2011.
I’d second Steve Mojo, executive director of the Biodegradable Products Institute: “The label is not talking about or conveying information about end-of-life” or compostability, Mojo said. “It is not a green program, but it will at least help people know what’s in the product.” [Plastics News Jan 24, 2011]
It’s good to have a definition of bio-based content, but it’s not necessarily a net life cycle benefit depending on how much it costs to grow and process the “renewable” material, how well it works and what can be done after end use. Pay attention to FTC Green Guides when making claims beyond simple statements of content. Will consumers figure the USDA label means “green” – somehow I think so.
The FTC just announced action against a company that provided bogus “Tested Green” certifications to customers for a fee. Press release here. Sounds like there could be some other laws the company violated too….
Don’t be taken in looking for a quick “green” claim. There are some legitimate 3rd party certifiers out there, but you really need to know your market and your competition and have facts to back up your claim.
The FTC Green Guides are pretty solid: make claims technically accurate and not misleading.
If you need help, contact EHS Strategies, Inc.
I have to agree, “sustainability” is a frustrating term now being used by anyone for anything (nearly 30 million hits on Google search!). Always an issue when marketing jumps on a term. See Triple Pundit’s article: http://www.triplepundit.com/2011/01/ad-age-names-sustainability-one-jargoniest-jargon-words-2010/
I also commented to the FTC that it shouldn’t be accepted as an environmental marketing claim.
See my other blogs on the topic of sustainability.