Environmental Marketing - What Constitutes a 'Green' Claim?
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Environmental Marketing - What Constitutes a 'Green' Claim?

Environmental marketing terms are proliferating. What does it take to make a substantiated "green" claim about either your facility or your product?

By Marcia Y. Kinter, Vice President - Government & Business Information, SGIA

Consumers of both industrial and commercial products are finding it increasingly difficult to wade through the terms and discern their true meanings. Is a "green" product better than one that is "environmentally-friendly?" These undefined descriptions have been in use for many years.

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  • It is difficult to open a magazine without seeing an advertisement making a "green" claim. The commonly accepted definition of a green claim is the explicit or implicit reference to the environmental or ecological impacts of production, distribution, use, consumption or disposal of a product or package. Within this framework, a green claim can communicate the effect of the product, its components or package regarding issues of solid waste, water, global warming, emissions of volatile organic compounds and/or air toxics, wildlife habitats and human health, among others. Additionally, a green claim may be construed to mean the absence, reduction or even the presence of a specific substance: Polyvinyl chloride (PVC) or phthalates, as examples.

    The flipside to environmental marketing is "greenwashing:" The act of misleading consumers regarding the environmental practices of a company or the environmental benefits of a product or service. TerraChoice Environmental has helped define this concept since the release of their first survey findings in 2007. In a recent update to the survey, they added a seventh sin to their greenwashing scorecard. Now known as the "Seven Sins of Greenwashing," their survey findings suggest that greenwashing is pervasive and the consequences are significant. The seven sins are as follows:

    1. Sin of Hidden Trade-Off
    2. Sin of Worshipping False Labels
    3. Sin of No Proof
    4. Sin of Vagueness
    5. Sin of Irrelevance
    6. Sin of Lesser of Two Evils
    7. Sin of Fibbing
    A significant question before many companies is how to navigate the minefield of environmental marketing. In the US, the primary guidelines for environmental marketing are offered by the Federal Trade Commission (FTC) in its "Green Guides for Marketing." The FTC's Environmental Guides are "administrative interpretations of laws administered by the Commission for the guidance of the public in conducting its affairs in conformity with legal requirements."

    These guides apply to all forms of marketing for products and services: Advertisements, labels, package inserts, promotional materials, words, symbols, logos, product brand names and marketing through digital or electronic media such as the Internet or email. They apply to any claim, expressed or implied, about the environmental attributes of a product, package or service in connection with the sale, offering for sale or marketing of the product, package or service for personal, family or household use or for commercial, institutional or industrial use.

    Making Claims
    When considering an environmental claim, adhering to a few basic principles may help. One principle is to evaluate claims from the consumer's perspective. Using this lens requires you to go beyond the actual meaning of the words to explore perceptions based on the use of the terms. When making claims, it is critical that all real or implied claims be backed up. This may require the use of objective tests, analyses, research or studies conducted by qualified individuals using generally accepted procedures. This would suggest that when making an environmental marketing claim, care should be taken to research and use the commonly accepted definitions and/or testing methods for each claim made.

    The use of broad environmental claims has emerged as the most common. These broad claims, such as earth-friendly, eco-friendly, environmentally-friendly or preferable conveys to the consumer that the product in question has a far-reaching environmental benefit. However, the benefit is not clearly defined or easy to substantiate and therefore is likely misleading.

    Another emerging area involves the use of claims that indicate that a product is free of a certain constituent. In this case, the following questions may arise in the mind of the consumer (using phthalates as an example): When advertised as phthalate-free, does this mean that the alternatives do not present any hazards? Is it truly free of the material in question? Did the product in question ever contain the material that has now been taken out? By considering these questions, you can see that these terms can be used to mislead consumers.

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    Probably one of the most commonly used but misunderstood terms is "recyclable." To be marketed properly as a recyclable product, it must be diverted from the solid waste stream and, most importantly, the product must be accepted by a recycling program that is available in a substantial majority of communities. To ensure that you present an accurate message, include statements on product packaging such as, "This product may not be recyclable in your area," or "Recycling programs for this product may not exist in your area." Conversely, avoid language such as, "Recyclable where facilities exist," or "Check to see if recycling facilities exist in your area." Recall that environmental advertising claims should be evaluated through consumers' eyes and you can see the need to research and validate claims made by companies.

    Recycled content is a different concept. Recycled content claims can be made based on either pre- or post-consumer recovered materials. A recycled content product is an item that contains recovered materials. Recovered materials are wastes that have been diverted from conventional disposal such as landfills. Recovered materials include both pre- and post-consumer wastes. Pre-consumer materials are generated by manufacturers and processors and may consist of scrap, trimmings and other byproducts that were never used in the consumer market.

    Post-consumer materials are end products that have completed their life cycle as consumer items and would otherwise be disposed of as solid waste. Post-consumer materials include recyclables collected in commercial and residential recycling programs such as office paper, cardboard, aluminum cans, plastics and metals.

    Recycled-content products may contain some pre-consumer waste, some post-consumer waste or both. A product does not have to contain 100 percent recovered materials to be considered recycled, but the higher the percentage of recycled content, the greater the amount of waste that is diverted from disposal. Products that contain less than 100 percent recycled content should be qualified.

    The most complex term to address is the use of the word "sustainable," because it incorporates the concepts of environmental, economic and social welfare. It is often coupled with the term "environmental." Unqualified sustainability claims deceive the public as to the specific nature of the benefit. This is where the Sustainable Green Printing (SGP) Partnership comes in to play.

    The SGP Partnership provides substance to a facility's sustainability claims. Under the SGP Partnership, claims are not made regarding products produced at a specific facility, but about sustainable business practices adopted by the facility. A printing facility engaged in the SGP Partnership subscribes to a clearly identified set of transparent criteria, including the development of a management system, adoption of a sustainability policy and adherence to a set of identified best management practices that spans the manufacturing process, facility operations and employment practices. To provide further credibility, the facility undergoes a third party certification audit. This system goes a long way toward substantiating sustainability claims made by a facility.

    Industries see a rise in the enforcement activities of the use of environmental marketing terms. The FTC recently settled cases regarding biodegradable and bamboo fiber claims, and in Europe, the European Union continues to investigate green claims.

    Making environmental claims, either at the product or process level, raises a complex set of issues regarding both facts and science. When making any claim, tell the truth and resist the temptation to exaggerate. Be specific and clear regarding any claims you make. Avoid making unsubstantiated claims, and be ready to back up what you are saying with good science and common sense. At the end of the day, consider what the customer and consumer will take away regarding your marketing message.

    Marcia Y. Kinter, SGIA's Vice President for Government & Business Information, oversees the Association's development of management resources. She represents the specialty imaging community and its associated supplier base before federal and state regulatory agencies and the US Congress on environmental, safety and other issues that directly impact the industry. marcik@sgia.org

    This article appeared in the SGIA Journal, 3rdd Quarter 2010 Issue and is reprinted with permission. Copyright 2010 Specialty Graphic Imaging Association (www.sgia.org). All Rights Reserved.

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