ANA Files Comments on Revised FTC Green Guides

On December 10, ANA filed comments on the proposed revisions to the FTC’s Guides for the Use of Environmental Marketing Claims, more commonly known as the Green Guides.  These revisions are the first since 1998 to the guidelines which help marketers make substantiated and truthful claims about the environmental attributes of products.  Our comments support the FTC’s approach in basing the changes on consumer data evidence.  However, our comments note a number of concerns we have with the guides.  Specifically, we are concerned about how the guides deal with substantiation of certain claims of general environmental benefits and how they approach certification and seal programs.  We also ask the FTC to reevaluate the guidance for recyclable, renewable material and degradable and compostable claims.

Our comments were drafted by John Feldman of Reed Smith LLP, the office of ANA’s General Counsel.

If you have any questions, you can reach Dan Jaffe in ANA's Washington office at 202-296-2359 or at