Amazon.com, Macy’s and Sears recently settled U.S. Federal Trade Commission lawsuits over claims the companies misled consumers about their “green” products. The suit alleged the retailers sold rayon fabrics labeled as made from bamboo fiber, when none of the plant’s unaltered fiber was woven into the fabric.
“You don’t want to be in that kind situation,” said Gale Tedhams, director of sustainability for Owens Corning, during her education session “Green Marketing” at COMPOSITES 2013. “As sustainability becomes more important to the composites industry, making the right choices can make the difference in being seen as a credible business or engaging in ‘greenwashing’” — providing misleading or false claims about your products.
The U.S. Federal Trade Commission (FTC) has a guideline for “Use of Environmental Marketing Claims,” Tedhams explained, and the document was revised in 2012 with specific language about what firms can and cannot do. She used the FTC guideline to illustrate examples of how to make environmental claims about composite products and processes.
“The purpose of the FTC guide is to make sure companies play fair and don’t deceive potential buyers,” Tedhams said. “When you’re making a claim, you need to make sure you qualify that claim. It’s important to be as specific as possible.” She suggested that attendees follow three general rules for green marketing:
- Qualifications and disclosures must be clear, prominent and understandable.
- Specify whether a claim refers to a product, the product’s packaging or portions of both.
- Claims shouldn’t overstate an environmental attribute.
She pointed out that the FTC revision in 2012 expanded false claim rules to business-to-business transactions and “marketing in any form,” including telephone on-hold messages, logos, product brand names and press releases. The revision states that a green marketing claim is deceptive if it’s likely to mislead a “consumer acting reasonably” and if the claim is likely to change a consumer’s purchasing decision.
Many attendees frenetically took notes as Tedhams listed what she called the “seven deadly sins of green marketing:”
- Sin of the Hidden Trade-off: suggesting a product is green on narrow attributes without attention to other environmental issues
- Sin of No Proof: making a claim that can’t be substantiated (underscoring the importance of third-party certification
- Sin of Vagueness: making a poorly defined or broad claim so meaning is misunderstood
- Sin of False Labels: giving a product the impression of a third-party endorsement when the product doesn’t have one
- Sin of Irrelevance: making a truthful claim, but one that isn’t important (for example, calling something “CFC-free!” when CFC is banned nationally).
- Sin of the Lesser of Two Evils: making a claim that’s true within a product category, but distracts from the greater impact of the product
- Sin of Fibbing: lying about a product’s greenness
“One big issue with many composites companies is use of generic words like “eco-friendly” and “green” — it’s clear that words indicating a general environmental benefit could be seen as deceptive because it’s too hard to substantiate,” Tedhams says, adding that Owens Corning now deletes those words in all product press releases.