FTC Green Marketing Guidelines: What You Need To Know


Conscious Connection Founder Anthony Chiaravallo recently caught up with Jacquie Ottman, America’s leading expert on green marketing, and a consultant with 25 years’ experience advising some of the nation’s best known brands on sustainability and eco-innovation, and author of award-winning book, The New Rules of Green Marketing.

Up for discussion was the publication of the Federal Trade Commission’s recently updated Guidelines for Environmental Marketing Claims for companies marketing environmentally preferable products, and the sweeping effects these may have on the way environmentally conscious goods can be branded and advertised.

A must-read for environmentally aware consumers and business owners alike, we share Jacquie’s insights and summary below.


The big news in the FTC’s latest Green Guides is that, from now on, any marketer who wants to make a claim about the overall “greenness” of one’s product will need to prove scientifically that the product is in fact environmentally superior to a competitor’s product or to a former version of the product itself, and get validation from a certified third party to back up those claims.  Because it is nearly impossible to prove that one’s product is greener than another, chances are that claims such as “Environmentally friendly”, “Planet-safe”, “Eco-friendly” and even just “Green” are all no longer valid.

And it doesn’t stop at specific word claims.  The new guides cover other aspects of a product’s public profile, from its brand name to the imagery used on packaging and advertising.  So it will be very important for marketers to curb the use of such images as the proverbial “babies, planets and daisies” which could give consumers the impression, too, that a product is overall “green”.

This is to discourage ambiguous terminology and assist consumers with their buying decisions – after all, just how “Green” is an energy saving light bulb containing mercury or even a Prius that may be fuel-efficient but it contains a lithium ion battery that constitutes a form of hazardous waste.

What’s the alternative? Marketers will now have to restrict themselves to making claims relating to specific attributes such as  ‘made from 30% recycled content’, or ‘ 10% more fuel efficient’ versus saying it’s ‘green’ or ecofriendly.


Also addressed in the latest round of FTC Green Guide updates is the practice of companies labeling their products with their own eco-labels. From now on, it must be crystal clear to the consumer who actually provided the ecolabel, and of course, preferably an independent third party (such as one of the many standards operated by government agencies such as the EPA and USDA) . And the third party must be identified on the certification logo, or else stated clearly on the package that it is the company’s own label, and no one else’s.

Terms that were not covered in the previous versions of Green Guides (which were first issued in 1992 and updated in 1996 and 1998), such as “made with renewable energy”, “made with renewable materials”, carbon offsets and compostable materials, are now addressed.

Guidance on the usage of some terms popular with green marketers such as “Energy-efficient” and “Organic” do not appear in the FTC’s update guidelines; instead, these terms are defined by other branches of the Federal Government (the EPA and USDA) and these agencies operate their own labeling programs. USDA now also has a label for “bio-based” products, which Jacquie herself helped the USDA to introduce in 2011.

Notably absent from the FTC’s latest guidelines are definitions for such terms as “Natural” and “Sustainable”. Though we can only speculate as to why these terms were not addressed, Jacquie offers a possible hypothesis. The label “Natural” has clear health connotations, being associated most frequently with food and health related products, and labeling relating to health falls outside the scope of the FTC’s Guide. Similarly, the term “Sustainable” is subject to a wide variety of possible interpretations, including economic and social as well as environmental sustainability, and the FTC’s guidance is restricted to the environmental aspect alone. It is also possible that the FTC considers “Sustainable” products to be synonymous with “Renewable” ones insofar as the guidelines are concerned, and the term “Renewable” does receive attention in the latest version of the Green Guides.

Ultimately, it will be up to companies and their marketers to decide how to adapt to the updated FTC guidelines for environmental marketing, and they can be expected to choose carefully which terms and standards to use. On this issue, Jacquie has another interesting observation. The three most popular environmentally-themed labels are the ubiquitous recycling logo, the Energy Star label, and USDA’s “Organic” certification. Aside from all representing popular attributes of green products, what do they all have in common? They are all free to use.


In this new phase of the FTC Green Guides (which of course are just guidance and not laws or regulation), Jacquie has some valuable tips for smaller companies whose marketers might be left wondering how best to manage their brands and advertising and avoid “greenwash”.

First and foremost, be specific. Avoid at all costs overly general claims about a product’s benefits, and focus instead on quantifiable, verifiable strengths and features that can be supported by third party certification.

Second, be clear. Avoid using terms or messaging that might leave consumers confused or with an inaccurate impression about the merits of your product. Under the updated Green Guides, marketers are being held responsible for the perceived – as well as the intended, communication of their claims.. For instance there is a great deal of confusion among consumers about the definitions of the terms “renewable”, “recyclable”, “recycled” and “biodegradable”. So. If your product is made from renewable materials, but is not recyclable, make sure to make this clear, and also note that recyclable products may only be recycled where appropriate facilities exist.

Be as complete as possible. Jacquie raises the case of a paint that was labeled free of VOCs. While the base paint was indeed free of VOCs, added colorants contain VOCs and since most paints contain colorants, a claim of no-VOCs was judged to be misleading.  Cases like these illustrate the importance of getting the right technical and legal advice to ensure your claims are fully compliant.

More information and advice on these issues is available directly from the FTC and the Advertising Self-Regulatory Council of the Better Business Bureau. Additionally, subscribe to our magazine for free resources and commentary on social business, sustainability and the eco-creative lifestyle.

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