http://csrwiretalkback.tumblr.com/post/365987629/localwashing-is-the-new-greenwashing
CSRwire is the leading source of corporate social responsibility and sustainability press releases, reports and information.
* Monday, Feb 01st, 10
Localwashing Is The New Greenwashing
How Local Is “Local”?
By Jeffrey Hollender
There’s no bandwagon corporate goliaths won’t jump on with an enthusiasm geared to make us think it was their idea all along. Start a trend, found a movement, make a wave, and you’ll soon find companies of all kinds working overtime to hijack it all the way to the bank.
When environmentalism got hot and consumers wanted to devote their dollars to more sustainable goods and services, the marketplace turned green almost overnight. Suddenly every product had an environmental benefit. Yet the vast majority were simply deceptively marketed poseurs. Such products (and they’re out there in droves) are said to be “greenwashing,” and now they’ve got some competition: products and companies that claim to be “local” when they’re anything but.
This “localwashing” is a predictable response to the new localvore movement, which emphasizes the environmental and economic importance of goods and services produced by members of one’s own community and those nearby. And it’s fast becoming the new greenwashing as the world’s largest corporations attempt to co-opt consumers’ growing desire keep their money closer to home where it can boost the fortunes of the local economy and the neighbors whose ventures fuel it.
That boost is a highly effective way for us to reverse all kinds of unfortunate trends, from too-big-to-fail corporate consolidation to unsustainable industrial-scale production techniques. A study by Civic Economics found that forty five cents of every dollar spent at a locally-owned business stays in the community. At a chain store, only thirteen cents remains behind. The rest ends up in distant pockets.
With that kind of economic power now understood by growing numbers of shoppers, it’s no wonder big companies are tripping all over each other in a rush to position themselves as “local.” HSBC, for example, the fifth largest bank on Earth, now sells itself as “the world’s local bank.” International consumer products giant Unilever is running ads for its Hellmann’s brand mayonnaise with the theme “eat real, eat local.” The International Council of Shopping Centers urges us to “shop local” at our nearest chain store-filled mall. And no less a corporate behemoth than Wal-Mart, the planet’s most un-local enterprise, is exploiting the fact that it occasionally stocks a token amount of regional produce (think blueberries in Maine) to establish localvore credibility.
Our own reaction to localwashing should be to scrutinize all claims of “localness.” We must shop with our eyes wide open and make sure that we aren’t being misled into patronizing companies and buying products with no legitimate community connection. (I’d suggest boycotting companies that make these claims, writing them letters of complaint and reporting them to the Better Business Bureau as well as the Attorney General.)
To avoid this localwashing we need only a little common sense. If a product looks like it comes from a far off factory, it probably does. If it doesn’t explicitly say it’s made nearby, it probably isn’t. If a food looks out of place, it’s probably from out-of-state. If a store is so big you need a cell phone to call across it or has outlets you can count on more than one hand, the only thing local about it is probably its parking lot. Logic like this will keep our localvore efforts authentic. And that’s something we should all buy into.
About Jeffrey Hollender
Jeffrey Hollender is co-founder and Executive Chairperson of Seventh Generation, a leading natural home products company. He’s the the author of several books, including What Matters Most and Naturally Clean. He is a member and former Director of the Social Venture Network, a group of socially-conscious business executives. Hollender served as President of The Rainforest Foundation USA from 1992 to 1996, an organization created to protect the rainforest and the human rights of its indigenous peoples. He also served as a Board member and Chairperson of the Board of Directors of Vermont Businesses for Social Responsibility.
Wednesday, February 3, 2010
Sunday, December 27, 2009
Carbon Offsets - not so green
It has been on my list for quite some time to research carbon offsets as to which are greenwashing, which have an effect immediately, which won't work for another 30 years, etc. What I had not considered was that some of the offsets themselves would actually be detrimental. Here is a great op ed in the NY Times that has opened my eyes and shows how planting trees is really not such a good idea.
http://www.nytimes.com/2009/12/20/opinion/20heinrich.html
Op-Ed Contributor
Clear-Cutting the Truth About Trees
By BERND HEINRICH
Published: December 19, 2009
Burlington, Vt.
THE Copenhagen climate-change summit meeting is behind us, and did not achieve what was hoped for. There was no lack of good intentions, but they generated conflicts rather than solutions, and the product was a weak agreement to disagree in the future. Forests were part of the discussion, and several things were understood: carbon dioxide is a potentially world-altering lethal pollutant, fossil fuels are the problem, biofuels are part of the solution. But exactly how to pare down the use of fossil fuels and switch to energy sources derived from plant material? That is the problem.
Biofuels are the indirect use of solar energy packaged into plants by the best solar-panel technology that has ever been invented, and it is far easier to grow green power than to build nuclear plants, dam our waterways and put windmills on our scenic mountaintops. Yet our current plans to shift to green energy — centered on so-called carbon offsets and cap-and-trade systems — are in some applications sorely misguided.
Contrary to what you might hear from energy companies and environmentally conscious celebrities, offsets don’t magically make carbon emissions disappear. Worse, relying on them to stem global warming may devastate our vital forest ecosystems.
On the industrial scale, carbon trading works like this: Limits (caps) are set on carbon emissions so that the true costs of our energy use are not just passed on to our descendants or people in some distant country. As an incentive to help the planet, savings of carbon emissions that one achieves below the designated cap can then be traded, as offsets, to another polluter who can then go over his cap by an equal amount. While carbon credits can be generated by switching to cleaner technology or nonpolluting sources in energy production, they can also be gained by unrelated steps, like planting trees, that are said to deter global warming.
Thus, if I burn coal in my business, I can plant pines in Chile and earn an offset, which will then allow me to burn even more coal. On a smaller scale, Al Gore purchases carbon offsets that he says make up for the emissions from the jets he uses in spreading his message of conservation. All this may seem logical, and energy companies would have you believe it works in the real world. But it is actually terrible for the planet, which is governed by the dictates of physics and biology.
Part of the problem is the public misunderstanding of how forests and carbon relate. Trees are often called a “carbon sink” — implying that they will sop up carbon from the atmosphere for all eternity. This is not true: the carbon they take up when they are alive is released after they die, whether from natural causes or by the hand of man. The only true solution to achieving global “carbon balance” is to leave the fossil carbon where it is — underground.
Beyond that, planting more trees is decidedly not the same thing as saving our forests. Instead, planting trees invariably means using them as a sustainable crop, which leads not only to a continuous cycle of carbon releases, but also to the increased destruction of our natural environment.
A few environmental groups in Copenhagen were considered unwelcome guests for loudly pointing out that the carbon-trading proposals bandied about at the meetings subsidize forest destruction and will lead to large-scale destruction of ecosystems and unprecedented “land grabs.” (Disclosure: my wife is a researcher for one of those groups.) But such claims are correct. More than anything, carbon offsets will allow rich countries to burn ever more fossil fuels under the “clean development mechanism” of the Kyoto Protocol, the system that sets the values, in terms of tons of carbon equivalent, of emission-reduction efforts.
In fact, most of the problems with the system can be traced back to the Kyoto Protocol, which was adopted in 1997. After much political wrangling, the Kyoto delegates decided that there would be no carbon-reduction credits for saving existing forests. Since planting new trees does get one credits, Kyoto actually created a rationale for clear-cutting old growth.
This is horrifying. The world’s forests are a key to our survival, and that of millions of other species. Not only are they critical to providing us with building material, paper, food, recreation and oxygen, they also ground us spiritually and connect us to our primal past. Never before in earth’s history have our forests been under such attack. And the global-warming folks at Copenhagen seem oblivious, buying into the corporate view of forests as an exploitable resource.
A forest is an ecosystem. It is not something planted. A forest grows on its own. There are many kinds of forests that will grow practically anywhere, each under its own special local conditions. When a tree falls, the race is on immediately to replace it. In the forests I study, there so many seeds and seedlings that if a square foot of ground space opens up, more than a hundred trees of many different species compete to grow there.
So if you want to plant a specific species of tree for lumber or for offsets, you’ll have to apply an (petroleum-based) herbicide repeatedly over its lifespan. If you hope to make a profit, you will plant a tree genetically engineered to grow quickly and resist disease. This is the path to domestication of a plant that needs to be ever coddled with fertilizers, herbicides, pesticides and fungicides. And not coincidentally, there will then be a market for its seeds, and all the chemicals needed to coddle the crop.
In the end, what was originally intended as a mechanism for slowing global warming has created huge economic pressure for ecocide. And there will be no objections from easily duped bleeding- heart “environmentalists,” who absolutely love tree planting because it sounds so “green.”
To preserve something it first has to be valued, and the most effective means of valuing it is to have a practical use for it. If the discussions in Copenhagen were any indication, mankind sees little value in forests, but much in tree plantations. (On the other hand, I admit that those of us who really do care about forests have not exactly been helpful. We have not encouraged selective harvesting from naturally occurring stands, which may be necessary.)
It is easy to scream bloody murder against tree planting as a means for biomass energy and industrial fiber production, but there then has to be an alternative (aside from the obvious one of energy conservation). We need either vastly fewer people or vastly more forests, along with a new definition of earth-friendly reforestation.
These new stands of growth — if managed as true forest rather than as a single-species, single-aged crops — would contain a mixture of mature and transitional-growth trees. Any tree cut down would immediately generate a race of others to replace it at that spot, and the winner will emerge from a natural selection of seeds and seedlings most suited to grow there. No, this isn’t the fastest way to build up carbon credits. But it is the only real way to preserve the planet, and ourselves.
Bernd Heinrich, emeritus professor at the University of Vermont, is the author of the forthcoming “Nesting Season.”
http://www.nytimes.com/2009/12/20/opinion/20heinrich.html
Op-Ed Contributor
Clear-Cutting the Truth About Trees
By BERND HEINRICH
Published: December 19, 2009
Burlington, Vt.
THE Copenhagen climate-change summit meeting is behind us, and did not achieve what was hoped for. There was no lack of good intentions, but they generated conflicts rather than solutions, and the product was a weak agreement to disagree in the future. Forests were part of the discussion, and several things were understood: carbon dioxide is a potentially world-altering lethal pollutant, fossil fuels are the problem, biofuels are part of the solution. But exactly how to pare down the use of fossil fuels and switch to energy sources derived from plant material? That is the problem.
Biofuels are the indirect use of solar energy packaged into plants by the best solar-panel technology that has ever been invented, and it is far easier to grow green power than to build nuclear plants, dam our waterways and put windmills on our scenic mountaintops. Yet our current plans to shift to green energy — centered on so-called carbon offsets and cap-and-trade systems — are in some applications sorely misguided.
Contrary to what you might hear from energy companies and environmentally conscious celebrities, offsets don’t magically make carbon emissions disappear. Worse, relying on them to stem global warming may devastate our vital forest ecosystems.
On the industrial scale, carbon trading works like this: Limits (caps) are set on carbon emissions so that the true costs of our energy use are not just passed on to our descendants or people in some distant country. As an incentive to help the planet, savings of carbon emissions that one achieves below the designated cap can then be traded, as offsets, to another polluter who can then go over his cap by an equal amount. While carbon credits can be generated by switching to cleaner technology or nonpolluting sources in energy production, they can also be gained by unrelated steps, like planting trees, that are said to deter global warming.
Thus, if I burn coal in my business, I can plant pines in Chile and earn an offset, which will then allow me to burn even more coal. On a smaller scale, Al Gore purchases carbon offsets that he says make up for the emissions from the jets he uses in spreading his message of conservation. All this may seem logical, and energy companies would have you believe it works in the real world. But it is actually terrible for the planet, which is governed by the dictates of physics and biology.
Part of the problem is the public misunderstanding of how forests and carbon relate. Trees are often called a “carbon sink” — implying that they will sop up carbon from the atmosphere for all eternity. This is not true: the carbon they take up when they are alive is released after they die, whether from natural causes or by the hand of man. The only true solution to achieving global “carbon balance” is to leave the fossil carbon where it is — underground.
Beyond that, planting more trees is decidedly not the same thing as saving our forests. Instead, planting trees invariably means using them as a sustainable crop, which leads not only to a continuous cycle of carbon releases, but also to the increased destruction of our natural environment.
A few environmental groups in Copenhagen were considered unwelcome guests for loudly pointing out that the carbon-trading proposals bandied about at the meetings subsidize forest destruction and will lead to large-scale destruction of ecosystems and unprecedented “land grabs.” (Disclosure: my wife is a researcher for one of those groups.) But such claims are correct. More than anything, carbon offsets will allow rich countries to burn ever more fossil fuels under the “clean development mechanism” of the Kyoto Protocol, the system that sets the values, in terms of tons of carbon equivalent, of emission-reduction efforts.
In fact, most of the problems with the system can be traced back to the Kyoto Protocol, which was adopted in 1997. After much political wrangling, the Kyoto delegates decided that there would be no carbon-reduction credits for saving existing forests. Since planting new trees does get one credits, Kyoto actually created a rationale for clear-cutting old growth.
This is horrifying. The world’s forests are a key to our survival, and that of millions of other species. Not only are they critical to providing us with building material, paper, food, recreation and oxygen, they also ground us spiritually and connect us to our primal past. Never before in earth’s history have our forests been under such attack. And the global-warming folks at Copenhagen seem oblivious, buying into the corporate view of forests as an exploitable resource.
A forest is an ecosystem. It is not something planted. A forest grows on its own. There are many kinds of forests that will grow practically anywhere, each under its own special local conditions. When a tree falls, the race is on immediately to replace it. In the forests I study, there so many seeds and seedlings that if a square foot of ground space opens up, more than a hundred trees of many different species compete to grow there.
So if you want to plant a specific species of tree for lumber or for offsets, you’ll have to apply an (petroleum-based) herbicide repeatedly over its lifespan. If you hope to make a profit, you will plant a tree genetically engineered to grow quickly and resist disease. This is the path to domestication of a plant that needs to be ever coddled with fertilizers, herbicides, pesticides and fungicides. And not coincidentally, there will then be a market for its seeds, and all the chemicals needed to coddle the crop.
In the end, what was originally intended as a mechanism for slowing global warming has created huge economic pressure for ecocide. And there will be no objections from easily duped bleeding- heart “environmentalists,” who absolutely love tree planting because it sounds so “green.”
To preserve something it first has to be valued, and the most effective means of valuing it is to have a practical use for it. If the discussions in Copenhagen were any indication, mankind sees little value in forests, but much in tree plantations. (On the other hand, I admit that those of us who really do care about forests have not exactly been helpful. We have not encouraged selective harvesting from naturally occurring stands, which may be necessary.)
It is easy to scream bloody murder against tree planting as a means for biomass energy and industrial fiber production, but there then has to be an alternative (aside from the obvious one of energy conservation). We need either vastly fewer people or vastly more forests, along with a new definition of earth-friendly reforestation.
These new stands of growth — if managed as true forest rather than as a single-species, single-aged crops — would contain a mixture of mature and transitional-growth trees. Any tree cut down would immediately generate a race of others to replace it at that spot, and the winner will emerge from a natural selection of seeds and seedlings most suited to grow there. No, this isn’t the fastest way to build up carbon credits. But it is the only real way to preserve the planet, and ourselves.
Bernd Heinrich, emeritus professor at the University of Vermont, is the author of the forthcoming “Nesting Season.”
Thursday, December 10, 2009
Understanding GHG Emission Numbers
http://www.darkoptimism.org/2008/09/03/the-climate-science-translation-guide/
I am taking a class in Sustainability Metrics and using the process of writing a paper to try to get a real understanding of the climate change terms being bantered around.
The link I posted is to an excellent post I found explaining the difference between CO2, CO2 equivalents and CO2 total. I think this is good information to know, esp. when talking to climate change disbelievers. I hate to admit it, but I do not fully understand some of the graphs in this document.
The climate science translation guide
by Shaun Chamberlin on September 3rd, 2008
Age Of Stupid Climate-o-meter
We are all familiar with the concept of climate change, and the need for reduced carbon emissions, but really getting a handle on the scale of the problem can be difficult, thanks to all the confusing terminology.
I looked all over the web for a straightforward comprehensive explanation of terms like Global Warming Potential (GWP) and the different meanings of CO2equivalent but I couldn’t find it, so eventually I decided to spend some of my time (and the time of many helpful friends and colleagues) on creating one.
I didn’t count on quite how intricate the underlying science is (it became ever clearer to me why there is so much confusion in this area), so the process took some considerable time, but I believe that this post is now something that many will find useful. It has been checked for accuracy by qualified experts.
In order to fully understand the relationship between greenhouse gas emissions and global temperature increase then, we first need to consider the concept of radiative forcing.
Radiative forcing illustrated
The Earth is continually receiving energy from the Sun, and continually losing energy into space (as space is much cooler than the Earth). Radiative forcing is simply the difference (measured in watts per square metre) between the amount of energy received and the amount of energy re-radiated back into space. In other words it is the rate at which the planet’s surface is either warming or cooling. [1]
If the planet were losing energy at the same rate it was gaining it then the radiative forcing would be zero and the temperature would remain stable at its current level – this state is called thermal equilibrium. Since a hotter planet loses more energy into space, the natural system tends to move towards thermal equilibrium.
However, rising greenhouse gas concentrations (measured in parts per million – ppm [2]) in the atmosphere act like an insulating blanket, reducing the rate at which energy can escape into space, and so affecting radiative forcing, which in turn affects the temperature. The rough illustrative graphs below give an idea of these relationships and show the time delay between changes in emissions rates (up or down) and temperature changes. [3]
Climate - Business As Usual
The graph below shows that if we can bring anthropogenic (human-caused) emissions back down we can stabilise greenhouse gas concentrations and bring radiative forcing back towards equilibrium, but at a higher temperature. [4]
Climate with emissions reductions
So, emissions contribute to greenhouse gas concentrations which in turn contribute to radiative forcing, but it is radiative forcing that determines the rate of change in temperature. Armed with this understanding, the terms below become clearer:
Global warming potential (GWP) is an estimate of how much a given greenhouse gas contributes to Earth’s radiative forcing. Carbon dioxide (CO2) has a GWP of 1, by definition, so a gas with a GWP of 50 would increase radiative forcing by 50 times as much as the same amount (mass) of CO2. A GWP value is defined over a specific time interval, so the length of this time interval must be stated to make the value meaningful (most researchers and regulators use 100 years).
For example, methane has a GWP of 72 over 20 years, but a lower GWP of 25 over 100 years. This is because it is very potent in the short-term but then breaks down to CO2 and water in the atmosphere, meaning that the longer the period you consider it over, the more similar its effect is to that of CO2 alone. [5]
Equivalent carbon dioxide (CO2e) is an estimate of the concentration of CO2 (in ppm) that would cause a given level of radiative forcing. [6]
For example, the IPCC’s[7] latest report in 2007 considered the effects of the main greenhouse gases currently present in our atmosphere and calculated a CO2e for these of around 455ppm (and rising). This means that (over a defined period) the radiative forcing effect of these gases at current concentrations is roughly equal to the effect a 455ppm concentration of CO2 alone would cause. This particular CO2e calculation takes into account the six major greenhouse gases considered under the Kyoto Protocol, and so may be labelled CO2e(Kyoto). [8]
However, the orange line in the graphs above represents the total radiative forcing of the planet. This is the important figure – the one that determines the rate of change in Earth’s temperature – and as well as the Kyoto gases it is also affected by other factors such as the effects of sulphate aerosols, ozone and cloud formations. The chart below quantifies the effect of each of these factors, and we can see that a number of them (those coloured blue) are actually negative forcings, which act to reduce the total radiative forcing. Because of these, the equivalent CO2 for all forcings combined - CO2e(Total) - is, thankfully, lower than CO2e(Kyoto). The IPCC’s latest figures give CO2e(Total) as roughly 375ppm. [9]
When we hear scientific debates between stabilisation scenarios of, say, 350ppm, 450ppm or 550ppm it is CO2e(Total) which is under discussion. So this 375ppm is the key number, but it has a far wider margin of error than the others. This is because it is relatively easy to measure the atmospheric concentrations of greenhouse gases, and the GWP of those gases, but considerably more difficult to account for all the effects that contribute to the ultimate CO2e(Total) radiative forcing over a given period. The column in the below chart labelled LOSU stands for the “Level Of Scientific Understanding” of the various forcings, and as we can see it is not universally high. [10]
IPCC Radiative forcings
Radiative forcing is the fundamental issue, but it is easy to see why most discussions revolve only around emissions – not only are CO2 emissions much the largest way in which humanity is changing the planet’s radiative forcing, but they are also easier to understand conceptually and easier to quantify than radiative forcing.
According to the IPCC atmospheric CO2 concentrations were 379ppm in 2005, which coincidentally happens to be close to our best estimate of 375ppm CO2e(Total). Unfortunately this coincidence also creates a good deal of confusion, as it is not always clear which measure an author is referring to – scientists often assume that this is obvious to their audience, and many others do not themselves fully understand the distinctions between CO2, CO2e(Kyoto) and CO2e(Total). [11]
The other source of confusion is that all of the numbers we have discussed are based on evolving science, and many can only be given approximately. For example, these are the IPCC’s given figures for the GWP of methane over 100 years, taken from their last three reports:
1995 - 2nd Assessment Report (SAR): Methane 100 year GWP = 21
2001 - 3rd Assessment Report (TAR): Methane 100 year GWP = 23
2007 - 4th Assessment Report (AR4): Methane 100 year GWP = 25
These changes are entirely appropriate – the values should become more accurate over time as new measurement methods or changes in scientific understanding develop – but it makes it important to check where any figures are sourced from. [12]
Where we are today
So let’s take stock. Below are the latest IPCC figures, which define the situation as it was in 2005:
CO2 = 379ppm (error range: minimal)
CO2e(Kyoto) = 455ppm (error range: 433-477ppm)
CO2e(Total) = 375ppm (error range: 311-435 ppm) [13]
Emissions are still increasing year-on-year (faster than projected in any of the IPCC’s scenarios) and atmospheric CO2 concentrations are currently rising by between 1.5 and 3 ppm each year. They are at roughly 385ppm in mid-2008. It is worth noting that the pre-industrial concentration of CO2 in our atmosphere was 278ppm and did not vary by more than 7ppm between the years 1000 and 1800 C.E. [14]
Global average (mean) temperature has already risen by around 0.8°C since pre-industrial times, and a minimum additional 0.6°C of warming is still due from emissions to date - the delay in warming being a consequence of the time-lags in the system discussed above. [15]
Ok, that’s it! If you followed everything here you should be well-equipped to consider the scientific discussion of climate change. Indeed, you may find you understand it better than some of those who write and speak about it!
Hopefully this post will provide a resource to aid wider understanding of the changes we are causing to our global climate system and the climate emergency we are facing. Should any inaccuracies come to light I will of course amend them.
This work forms part of my forthcoming book The Transition Timeline, produced in partnership with the Transition Network, and set for publication in March 2009 available now from Green Books. It uses the understanding outlined here to examine the wider context of climate change and peak oil, discuss the options facing our communities and consider the cultural stories which underlie our choices.
Climate change with scientific realism
Footnotes
1. There is also a warming effect from the geothermal energy at the Earth’s core, but this is sufficiently small and stable that for our purposes we can ignore it.
2. Parts per million is the ratio of the number of greenhouse gas molecules to the total number of molecules of dry air. For example, 300ppm means 300 molecules of a greenhouse gas per million molecules of dry air. Strictly speaking concentrations are measured in parts per million by volume (ppmv), but this is widely abbreviated to ppm. Don’t be confused if some papers refer to ppmv.
3. Emissions are not the sole determinant of atmospheric greenhouse gas concentrations due to the Earth’s natural ‘carbon sinks’ which soak up some of our emissions. Concentrations are not the sole determinants of radiative forcing due to other forcings which will be discussed shortly. The time delay between radiative forcing and temperature increase is caused by the thermal inertia of the planet – it has great mass (with much of the heat initially being used to warm the deep oceans) and therefore takes some time to warm or cool. Of the (equilibrium) temperature increase ultimately produced by a given increase in radiative forcing, only about half manifests within 25 years, the next quarter takes 150 years to manifest, and the last quarter many centuries.
4. These illustrative graphs do not include the effects of climate feedbacks such as carbon sink degradation. Also see the MIT Climate Online ‘Greenhouse Gas Emissions Simulator’
5. Figures from: IPCC AR4 Working Group I Report, Chapter 2 , Table 2.14, p. 212.
More detail on GWP available at: http://en.wikipedia.org/wiki/Global_warming_potential - note that the GWP for a mixture of gases cannot be determined from the GWP of the constituent gases by any form of simple linear addition.
6. There is also a separate but related concept called Carbon Dioxide equivalent. This gives the amount of CO2 that would have the same GWP as a given amount of a given gas (or mixture of gases). It is simply calculated by multiplying the GWP of the gas by the given amount (mass) of gas. For example, over a 100 year period methane has a GWP of 25, so 1 gram of methane has a Carbon Dioxide equivalent value of 25 grams.
In practice, since Carbon Dioxide equivalent is expressed as a mass (grams, tonnes etc.), and Equivalent Carbon Dioxide (CO2e) is expressed as a concentration (usually in parts per million), they are not easily confused, despite the similar names.
You may also encounter references to the “carbon equivalent”, especially when discussing carbon that is not in gaseous form (e.g. carbon in coal deposits). A carbon equivalent figure can be converted to carbon dioxide equivalent by multiplying by 3.644 to account for the different molecular weights (3.644 tonnes of CO2 contains 1 tonne of carbon).
7. The IPCC is the Intergovernmental Panel on Climate Change - the body established jointly by the United Nations and the World Meteorological Organisation in 1988 to assess the available scientific evidence.
8. The IPCC considered the so-called ‘Kyoto basket’ of greenhouse gases (GHGs). Under the Kyoto Protocol, signatories committed to control emissions of a ‘basket’ of six GHGs - carbon dioxide, methane, nitrous oxide, HFCs, PFCs and SF6.
455ppm figure from e.g.: IPCC AR4 Working Group III Report, Chapter 1 , p.102
The IPCC estimate of CO2e(Kyoto) is detailed by Gavin Schmidt of NASA in a post at Real Climate
9. These negative forcings include the so-called ‘global dimming’ effect. For more on this crucial consideration see: “On avoiding dangerous anthropogenic interference with the climate system: Formidable challenges ahead”, V. Ramanathan and Y. Feng, Proceedings of the National Academy of Sciences, vol. 105, 23 September 2008, pp. 14245-14250
IPCC CO2e(Total) figure: IPCC AR4 Synthesis Report, notes to Table 5.1, p.67
10. Table source: IPCC AR4 Working Group I Report, Summary for Policymakers, Figure SPM.2, p.4
11. IPCC 2005 CO2 levels: IPCC AR4 Synthesis Report, Summary for Policymakers, p. 5
12. IPCC 2001 figures: IPCC TAR Working Group I Report, Chapter 6, Table 6.7
1995/2007: IPCC AR4 Working Group I Report, Chapter 2 , Table 2.14, p. 212
13. Error ranges: IPCC AR4 Working Group III Report, Chapter 1 , p.102
14. Up-to-date measurements of atmospheric CO2 concentrations are always subject to revisions, pending recalibrations of reference gases and other quality control checks. Trends and 2008 figure taken from: NOAA Earth System Research Laboratory - Global Monitoring Division (site accessed August 2008)
Pre-industrial CO2 levels from: NOAA (US National Oceanic and Atmospheric Administration)
15. See footnote [3] above for details on climate time-lags. Figure for warming from emissions to date taken from the Climate Code Red report by Carbon Equity, p.22.
Also see IPCC AR4 Working Group III Report, Summary for Policymakers, Table SPM.5, p.15 for ultimate (equilibrium) warming from current atmospheric concentrations.
Finally, note that a 2008 paper in the Proceedings of the National Academy of Sciences examined the impacts of air pollution (which blocks sunlight and thus reduces temperatures – the effect known as ‘global dimming’) and found that this is masking the full extent of the warming effect from greenhouse gas concentrations. Building on the IPCC’s work, the paper finds that if air pollution reduces – as it is expected to do – then 2005 atmospheric concentrations could commit us to around 2.4 degrees of warming above pre-industrial temperatures, with about 90% of this warming taking place this century.
Images
1. Climate-o-meter used (in edited form) with permission from http://www.ageofstupid.net/
2. Radiative forcing illustration used with permission from David Wasdell
3. Indicative climate graph created by author in partnership with David Wasdell, and with assistance gratefully acknowledged from Ben Brangwyn.
4. Indicative climate graph created by author in partnership with David Wasdell, and with assistance gratefully acknowledged from Ben Brangwyn.
5. Radiative forcings table from: IPCC AR4 Working Group I Report, Summary for Policymakers, Figure SPM.2, p.4
6. Indicative climate graph created by author in partnership with David Wasdell, and with assistance gratefully acknowledged from Ben Brangwyn.
I am taking a class in Sustainability Metrics and using the process of writing a paper to try to get a real understanding of the climate change terms being bantered around.
The link I posted is to an excellent post I found explaining the difference between CO2, CO2 equivalents and CO2 total. I think this is good information to know, esp. when talking to climate change disbelievers. I hate to admit it, but I do not fully understand some of the graphs in this document.
The climate science translation guide
by Shaun Chamberlin on September 3rd, 2008
Age Of Stupid Climate-o-meter
We are all familiar with the concept of climate change, and the need for reduced carbon emissions, but really getting a handle on the scale of the problem can be difficult, thanks to all the confusing terminology.
I looked all over the web for a straightforward comprehensive explanation of terms like Global Warming Potential (GWP) and the different meanings of CO2equivalent but I couldn’t find it, so eventually I decided to spend some of my time (and the time of many helpful friends and colleagues) on creating one.
I didn’t count on quite how intricate the underlying science is (it became ever clearer to me why there is so much confusion in this area), so the process took some considerable time, but I believe that this post is now something that many will find useful. It has been checked for accuracy by qualified experts.
In order to fully understand the relationship between greenhouse gas emissions and global temperature increase then, we first need to consider the concept of radiative forcing.
Radiative forcing illustrated
The Earth is continually receiving energy from the Sun, and continually losing energy into space (as space is much cooler than the Earth). Radiative forcing is simply the difference (measured in watts per square metre) between the amount of energy received and the amount of energy re-radiated back into space. In other words it is the rate at which the planet’s surface is either warming or cooling. [1]
If the planet were losing energy at the same rate it was gaining it then the radiative forcing would be zero and the temperature would remain stable at its current level – this state is called thermal equilibrium. Since a hotter planet loses more energy into space, the natural system tends to move towards thermal equilibrium.
However, rising greenhouse gas concentrations (measured in parts per million – ppm [2]) in the atmosphere act like an insulating blanket, reducing the rate at which energy can escape into space, and so affecting radiative forcing, which in turn affects the temperature. The rough illustrative graphs below give an idea of these relationships and show the time delay between changes in emissions rates (up or down) and temperature changes. [3]
Climate - Business As Usual
The graph below shows that if we can bring anthropogenic (human-caused) emissions back down we can stabilise greenhouse gas concentrations and bring radiative forcing back towards equilibrium, but at a higher temperature. [4]
Climate with emissions reductions
So, emissions contribute to greenhouse gas concentrations which in turn contribute to radiative forcing, but it is radiative forcing that determines the rate of change in temperature. Armed with this understanding, the terms below become clearer:
Global warming potential (GWP) is an estimate of how much a given greenhouse gas contributes to Earth’s radiative forcing. Carbon dioxide (CO2) has a GWP of 1, by definition, so a gas with a GWP of 50 would increase radiative forcing by 50 times as much as the same amount (mass) of CO2. A GWP value is defined over a specific time interval, so the length of this time interval must be stated to make the value meaningful (most researchers and regulators use 100 years).
For example, methane has a GWP of 72 over 20 years, but a lower GWP of 25 over 100 years. This is because it is very potent in the short-term but then breaks down to CO2 and water in the atmosphere, meaning that the longer the period you consider it over, the more similar its effect is to that of CO2 alone. [5]
Equivalent carbon dioxide (CO2e) is an estimate of the concentration of CO2 (in ppm) that would cause a given level of radiative forcing. [6]
For example, the IPCC’s[7] latest report in 2007 considered the effects of the main greenhouse gases currently present in our atmosphere and calculated a CO2e for these of around 455ppm (and rising). This means that (over a defined period) the radiative forcing effect of these gases at current concentrations is roughly equal to the effect a 455ppm concentration of CO2 alone would cause. This particular CO2e calculation takes into account the six major greenhouse gases considered under the Kyoto Protocol, and so may be labelled CO2e(Kyoto). [8]
However, the orange line in the graphs above represents the total radiative forcing of the planet. This is the important figure – the one that determines the rate of change in Earth’s temperature – and as well as the Kyoto gases it is also affected by other factors such as the effects of sulphate aerosols, ozone and cloud formations. The chart below quantifies the effect of each of these factors, and we can see that a number of them (those coloured blue) are actually negative forcings, which act to reduce the total radiative forcing. Because of these, the equivalent CO2 for all forcings combined - CO2e(Total) - is, thankfully, lower than CO2e(Kyoto). The IPCC’s latest figures give CO2e(Total) as roughly 375ppm. [9]
When we hear scientific debates between stabilisation scenarios of, say, 350ppm, 450ppm or 550ppm it is CO2e(Total) which is under discussion. So this 375ppm is the key number, but it has a far wider margin of error than the others. This is because it is relatively easy to measure the atmospheric concentrations of greenhouse gases, and the GWP of those gases, but considerably more difficult to account for all the effects that contribute to the ultimate CO2e(Total) radiative forcing over a given period. The column in the below chart labelled LOSU stands for the “Level Of Scientific Understanding” of the various forcings, and as we can see it is not universally high. [10]
IPCC Radiative forcings
Radiative forcing is the fundamental issue, but it is easy to see why most discussions revolve only around emissions – not only are CO2 emissions much the largest way in which humanity is changing the planet’s radiative forcing, but they are also easier to understand conceptually and easier to quantify than radiative forcing.
According to the IPCC atmospheric CO2 concentrations were 379ppm in 2005, which coincidentally happens to be close to our best estimate of 375ppm CO2e(Total). Unfortunately this coincidence also creates a good deal of confusion, as it is not always clear which measure an author is referring to – scientists often assume that this is obvious to their audience, and many others do not themselves fully understand the distinctions between CO2, CO2e(Kyoto) and CO2e(Total). [11]
The other source of confusion is that all of the numbers we have discussed are based on evolving science, and many can only be given approximately. For example, these are the IPCC’s given figures for the GWP of methane over 100 years, taken from their last three reports:
1995 - 2nd Assessment Report (SAR): Methane 100 year GWP = 21
2001 - 3rd Assessment Report (TAR): Methane 100 year GWP = 23
2007 - 4th Assessment Report (AR4): Methane 100 year GWP = 25
These changes are entirely appropriate – the values should become more accurate over time as new measurement methods or changes in scientific understanding develop – but it makes it important to check where any figures are sourced from. [12]
Where we are today
So let’s take stock. Below are the latest IPCC figures, which define the situation as it was in 2005:
CO2 = 379ppm (error range: minimal)
CO2e(Kyoto) = 455ppm (error range: 433-477ppm)
CO2e(Total) = 375ppm (error range: 311-435 ppm) [13]
Emissions are still increasing year-on-year (faster than projected in any of the IPCC’s scenarios) and atmospheric CO2 concentrations are currently rising by between 1.5 and 3 ppm each year. They are at roughly 385ppm in mid-2008. It is worth noting that the pre-industrial concentration of CO2 in our atmosphere was 278ppm and did not vary by more than 7ppm between the years 1000 and 1800 C.E. [14]
Global average (mean) temperature has already risen by around 0.8°C since pre-industrial times, and a minimum additional 0.6°C of warming is still due from emissions to date - the delay in warming being a consequence of the time-lags in the system discussed above. [15]
Ok, that’s it! If you followed everything here you should be well-equipped to consider the scientific discussion of climate change. Indeed, you may find you understand it better than some of those who write and speak about it!
Hopefully this post will provide a resource to aid wider understanding of the changes we are causing to our global climate system and the climate emergency we are facing. Should any inaccuracies come to light I will of course amend them.
This work forms part of my forthcoming book The Transition Timeline, produced in partnership with the Transition Network, and set for publication in March 2009 available now from Green Books. It uses the understanding outlined here to examine the wider context of climate change and peak oil, discuss the options facing our communities and consider the cultural stories which underlie our choices.
Climate change with scientific realism
Footnotes
1. There is also a warming effect from the geothermal energy at the Earth’s core, but this is sufficiently small and stable that for our purposes we can ignore it.
2. Parts per million is the ratio of the number of greenhouse gas molecules to the total number of molecules of dry air. For example, 300ppm means 300 molecules of a greenhouse gas per million molecules of dry air. Strictly speaking concentrations are measured in parts per million by volume (ppmv), but this is widely abbreviated to ppm. Don’t be confused if some papers refer to ppmv.
3. Emissions are not the sole determinant of atmospheric greenhouse gas concentrations due to the Earth’s natural ‘carbon sinks’ which soak up some of our emissions. Concentrations are not the sole determinants of radiative forcing due to other forcings which will be discussed shortly. The time delay between radiative forcing and temperature increase is caused by the thermal inertia of the planet – it has great mass (with much of the heat initially being used to warm the deep oceans) and therefore takes some time to warm or cool. Of the (equilibrium) temperature increase ultimately produced by a given increase in radiative forcing, only about half manifests within 25 years, the next quarter takes 150 years to manifest, and the last quarter many centuries.
4. These illustrative graphs do not include the effects of climate feedbacks such as carbon sink degradation. Also see the MIT Climate Online ‘Greenhouse Gas Emissions Simulator’
5. Figures from: IPCC AR4 Working Group I Report, Chapter 2 , Table 2.14, p. 212.
More detail on GWP available at: http://en.wikipedia.org/wiki/Global_warming_potential - note that the GWP for a mixture of gases cannot be determined from the GWP of the constituent gases by any form of simple linear addition.
6. There is also a separate but related concept called Carbon Dioxide equivalent. This gives the amount of CO2 that would have the same GWP as a given amount of a given gas (or mixture of gases). It is simply calculated by multiplying the GWP of the gas by the given amount (mass) of gas. For example, over a 100 year period methane has a GWP of 25, so 1 gram of methane has a Carbon Dioxide equivalent value of 25 grams.
In practice, since Carbon Dioxide equivalent is expressed as a mass (grams, tonnes etc.), and Equivalent Carbon Dioxide (CO2e) is expressed as a concentration (usually in parts per million), they are not easily confused, despite the similar names.
You may also encounter references to the “carbon equivalent”, especially when discussing carbon that is not in gaseous form (e.g. carbon in coal deposits). A carbon equivalent figure can be converted to carbon dioxide equivalent by multiplying by 3.644 to account for the different molecular weights (3.644 tonnes of CO2 contains 1 tonne of carbon).
7. The IPCC is the Intergovernmental Panel on Climate Change - the body established jointly by the United Nations and the World Meteorological Organisation in 1988 to assess the available scientific evidence.
8. The IPCC considered the so-called ‘Kyoto basket’ of greenhouse gases (GHGs). Under the Kyoto Protocol, signatories committed to control emissions of a ‘basket’ of six GHGs - carbon dioxide, methane, nitrous oxide, HFCs, PFCs and SF6.
455ppm figure from e.g.: IPCC AR4 Working Group III Report, Chapter 1 , p.102
The IPCC estimate of CO2e(Kyoto) is detailed by Gavin Schmidt of NASA in a post at Real Climate
9. These negative forcings include the so-called ‘global dimming’ effect. For more on this crucial consideration see: “On avoiding dangerous anthropogenic interference with the climate system: Formidable challenges ahead”, V. Ramanathan and Y. Feng, Proceedings of the National Academy of Sciences, vol. 105, 23 September 2008, pp. 14245-14250
IPCC CO2e(Total) figure: IPCC AR4 Synthesis Report, notes to Table 5.1, p.67
10. Table source: IPCC AR4 Working Group I Report, Summary for Policymakers, Figure SPM.2, p.4
11. IPCC 2005 CO2 levels: IPCC AR4 Synthesis Report, Summary for Policymakers, p. 5
12. IPCC 2001 figures: IPCC TAR Working Group I Report, Chapter 6, Table 6.7
1995/2007: IPCC AR4 Working Group I Report, Chapter 2 , Table 2.14, p. 212
13. Error ranges: IPCC AR4 Working Group III Report, Chapter 1 , p.102
14. Up-to-date measurements of atmospheric CO2 concentrations are always subject to revisions, pending recalibrations of reference gases and other quality control checks. Trends and 2008 figure taken from: NOAA Earth System Research Laboratory - Global Monitoring Division (site accessed August 2008)
Pre-industrial CO2 levels from: NOAA (US National Oceanic and Atmospheric Administration)
15. See footnote [3] above for details on climate time-lags. Figure for warming from emissions to date taken from the Climate Code Red report by Carbon Equity, p.22.
Also see IPCC AR4 Working Group III Report, Summary for Policymakers, Table SPM.5, p.15 for ultimate (equilibrium) warming from current atmospheric concentrations.
Finally, note that a 2008 paper in the Proceedings of the National Academy of Sciences examined the impacts of air pollution (which blocks sunlight and thus reduces temperatures – the effect known as ‘global dimming’) and found that this is masking the full extent of the warming effect from greenhouse gas concentrations. Building on the IPCC’s work, the paper finds that if air pollution reduces – as it is expected to do – then 2005 atmospheric concentrations could commit us to around 2.4 degrees of warming above pre-industrial temperatures, with about 90% of this warming taking place this century.
Images
1. Climate-o-meter used (in edited form) with permission from http://www.ageofstupid.net/
2. Radiative forcing illustration used with permission from David Wasdell
3. Indicative climate graph created by author in partnership with David Wasdell, and with assistance gratefully acknowledged from Ben Brangwyn.
4. Indicative climate graph created by author in partnership with David Wasdell, and with assistance gratefully acknowledged from Ben Brangwyn.
5. Radiative forcings table from: IPCC AR4 Working Group I Report, Summary for Policymakers, Figure SPM.2, p.4
6. Indicative climate graph created by author in partnership with David Wasdell, and with assistance gratefully acknowledged from Ben Brangwyn.
Wednesday, November 18, 2009
Is Bamboo flooring Greenwashing?
I am following a question on the Green Building Products Linked in group that someone else posed. I asked about FSC bamboo. Here is a very interesting reply. It looks like a life cycle analysis of bamboo flooring is on order....
Degree of Green to my website http://www.degreeofgreen.com
- Group: Green Building Products
- Subject: New comment (8) on "Why is Bamboo flooring considered a green floor? Sure bamboo is a sustainable in it's raw form, but shouldn't we take into account the toxins in the glues and solvents used to make the final product?"
I created a green building product rating system a couple years ago that is being used by manufacturers and retailers all across the US. This has got to be the #1 question I get. There are a few points to consider when determining the Degree of Green(R) of bamboo flooring:
1. Human Health - most bamboo flooring materials contain added urea formaldehyde in the adhesives that bind the product together...some are free of added urea formaldehyde. ALSO, containers shipped from China are routinely sprayed with pesticides, which can cause severe reactions to those with chemical sensitivities.
2. Environmental Heath - All bamboo comes from SE Asia, which means massive carbon emissions to transport to the US. No good study has been done on the environmental impact of the bamboo harvesting industry.
3. Sustainability - Yes, bamboo grows fast. However, farmers in China are clear cutting thousands of acres of trees to plant bamboo, since the US is so bamboo crazy. Not to mention, traditional bamboo flooring is not nearly as durable as we all thought it was when it came out 10 years ago. Exception given to the new strand woven product. Although, one can argue that the strand products are basically a mixture of bamboo and plastics. Not very green.
4. WIld Cards - Do the Chinese companies pay a fair wage? are they using child labor? What pesticides DO they use? etc, etc.
Regarding VOC's - Please understand that VOC's are only regulated by the EPA because some of them can react with nitrogen and UV to create low-level smog. VOC's are not all hazardous to humans. If you peel the skin off of an orange, you'll be subject to many more VOC's that you'd find in any bamboo floor. Not all VOC's are toxins...not all toxins are VOC's. Inside a home, we should be much more concerned about the toxicity of the products we use, not the VOC content.
IMHO, bamboo flooring is greenwashing in its purest form. But if you like the look of it, then buy it. But don't fool yourself into thinking its a green floor.
Posted by Andrew Pace
Degree of Green to my website http://www.degreeofgreen.com
Saturday, October 31, 2009
Exterior House Paints - green for the money?
As our remodel saga continues, when faced with a decision on materials I am researching the option with the least envirnomental impact and cost effective. I've found that nothing is simple, everything has multiple issues, it is so hard to find any good info.
So my latest is exterior house paint. By now everyone has heard of no and low VOC paints. Time to set some things straight:
1. The VOCs that are being taken out are to reduce smog and low level ozone depletion. This has nothing to do with toxicity.
2. Most people are concerned with the VOCs because of the outgassing and awful smells - indoor pollution - but really there could be lots of things outgassing making that smell that have nothing to do with VOCs.
3. There is very little data, reviews, etc. on EXTERIOR house paint because you won't smell it, like inside your home. But actually, that is where VOCs matter the most.
4. The paint base may be VOC low or no, but the pigments themselves give off VOCs. If you really want a no VOC product, you have to find one where they also claim that the pigments were designed also to be no VOC.
5. Due to Federal Laws, upcoming Federal laws, and CA state laws all paint manufacturers have generally gotten rid of their VOCs. They are at or below the legal limits. So further claims will become greenwashing because they will simply be complying with the law.
6. Other chemicals you want to avoid : acetone, ammonia, formaldehyde, formaldehyde formation during the curing process. I called the big 3 paint companies, all of them have none of these except trace amounts of ammonia.
7. I could find no testing where someone took the exterior house paints, green and non green, and actually measured some performance or compared them. Consumer Reports has a long term study - 3, 6, 9. 12 years - of paints. Most of the green paints came out in the past 3-5 years, so they are not in the consumer reports study.
Note: I have personally bought items highly rated by CR and been very disappointed. I think a second opinion is needed.
Bottom Line:
For exterior house paints, for greenness, all of the various brands of paints are the same. Also, I think that green and non green exterior paints are basically the same. You buy based on Quality, not on greenness. If you buy high quality, you will paint less often, which will use up less resources. High quality paints are 2x more expensive and there is little or no info on whether they really are higher quality. For this you have to rely on word of mouth from painting contractors.
Note: Paint company warranties are WORTHLESS. The cost of painting is in the prep and labor, not the materials. So if you pay $10K for a paint job and you pay $800 for the paint, and the paint fails - you still get to pay $9.2K. Even then, you have to provide all kinds of proof that the paint was used according to manufacturers specs, etc. etc.
So my latest is exterior house paint. By now everyone has heard of no and low VOC paints. Time to set some things straight:
1. The VOCs that are being taken out are to reduce smog and low level ozone depletion. This has nothing to do with toxicity.
2. Most people are concerned with the VOCs because of the outgassing and awful smells - indoor pollution - but really there could be lots of things outgassing making that smell that have nothing to do with VOCs.
3. There is very little data, reviews, etc. on EXTERIOR house paint because you won't smell it, like inside your home. But actually, that is where VOCs matter the most.
4. The paint base may be VOC low or no, but the pigments themselves give off VOCs. If you really want a no VOC product, you have to find one where they also claim that the pigments were designed also to be no VOC.
5. Due to Federal Laws, upcoming Federal laws, and CA state laws all paint manufacturers have generally gotten rid of their VOCs. They are at or below the legal limits. So further claims will become greenwashing because they will simply be complying with the law.
6. Other chemicals you want to avoid : acetone, ammonia, formaldehyde, formaldehyde formation during the curing process. I called the big 3 paint companies, all of them have none of these except trace amounts of ammonia.
7. I could find no testing where someone took the exterior house paints, green and non green, and actually measured some performance or compared them. Consumer Reports has a long term study - 3, 6, 9. 12 years - of paints. Most of the green paints came out in the past 3-5 years, so they are not in the consumer reports study.
Note: I have personally bought items highly rated by CR and been very disappointed. I think a second opinion is needed.
Bottom Line:
For exterior house paints, for greenness, all of the various brands of paints are the same. Also, I think that green and non green exterior paints are basically the same. You buy based on Quality, not on greenness. If you buy high quality, you will paint less often, which will use up less resources. High quality paints are 2x more expensive and there is little or no info on whether they really are higher quality. For this you have to rely on word of mouth from painting contractors.
Note: Paint company warranties are WORTHLESS. The cost of painting is in the prep and labor, not the materials. So if you pay $10K for a paint job and you pay $800 for the paint, and the paint fails - you still get to pay $9.2K. Even then, you have to provide all kinds of proof that the paint was used according to manufacturers specs, etc. etc.
Wednesday, October 14, 2009
Environmental Marketing Guidelines - FTC
http://www.use-less-stuff.com/Environmental-Marketing-Guidelines.pdf
http://www.use-less-stuff.com/Environmental-Marketing-Guidelines.pdf
Environmental Marketing Guidelines
Prepared By Robert M. Lilienfeld, Editor
The Use Less Stuff Report
I. INTRODUCTION
The marketplace increasingly demands products that deliver high levels of functionality with reduced levels of environmental impact. Businesses are looking for ways to meet these demands, and in so doing must effectively communicate both the functional and environmental benefits of their offerings.
On the functional side, strong companies usually have a history of providing customers with data that support their product claims. Over time, this has become increasingly easier to do, as customers today are quite knowledgeable about the information needed to make decisions.
The environmental side is quite different, as benefits such as “more sustainable,” “greener,” and “eco-friendly” cannot be assigned numerical values, since they are qualitative in nature. Also, as of yet there are no agreed-upon mechanisms or third party organizations that can evaluate these types of claims or enforce protocols, methodologies, and use of terms. Significantly, environmental claims are different in a third way. Unlike functional benefits, which become a tangible part of your customers’ products, environmental benefits have the potential to be communicated by your customers as part of the marketing message to their customers. This means that companies must work hard to meet regulations and legislation designed to protect “consumers” at all levels.
II. THE BASICS
The key body of U.S. law and regulations governing marketing communications is The Federal Trade Commission Act of 1914, which established its namesake, the FTC. Section 5 of the Act prohibits “unfair methods of competition” and was amended in 1938 to also prohibit “unfair or deceptive acts or practices.” A representation, omission, or practice is deceptive if: (1) it is likely to mislead consumers acting reasonably under the circumstances; and (2) it is likely to affect
consumers’ conduct or decisions with respect to the product at issue.
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Further, the FTC works jointly with the Environmental Protection Agency (EPA) to ensure that an organization’s environmental claims meet legal requirements. The EPA is as concerned about business-to-business activities as it is about business-to-consumer communications, as its literature regarding “deception” specifically calls out advertising, labeling, catalogs and sales presentationsi.
III. THE BIG PICTURE
Listed below are the four areas that are of most concern to the FTC regarding advertising claims of all types, but specifically those relating to the environment. Please keep in mind that the FTC makes it clear that you must comply with all of these concerns, not just those you feel are most advantageous or especially relevant to your product or message:
1. The single most important point to remember when making claims is to be as specific as possible. Doing so will require that claims be substantiated by communicating all of the following:
• What is being claimed -- Reduced energy consumption during production
• By how much -- By 12%
• Compared to what -- Versus the previous product formulation
Claims that are general or vague are not only considered to be meaningless, the FTC considers them to be deceptive. Technically, this means that claims which appear to be simple and harmless, such as “eco-friendly” and “green,” are actually open to scrutiny and legal action at the federal level. Such action can occur when the FTC is made aware of claims, either by their reviewing your materials or, more likely, via complaints from competitors, special interest
groups, state attorneys general, etc.
2. To further prevent deception, any qualifications or disclosures relating to your claims should be clear, prominent and easily understood. According to the FTC, “Clarity of language, relative type size and proximity to the claim being qualified, and an absence of contrary claims that could undercut effectiveness, will maximize the likelihood that the qualifications and disclosures are
appropriately clear and prominent.” ii
3. Environmental claims, attributes and benefits should not be explicitly or implicitly overstated. This requires that both the absolute and relative merits of a claim be considered.
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• Example: Claiming that a package has been reduced in weight by 50% would be considered deceptive by the FTC if the package in question now weighed 1 gram, versus 2 grams in the past. However, a 50% move from 16 oz. to 8 oz. would probably be considered acceptable, based upon the absolute change in question.
• Example: A resin is described simply as being “recyclable.” However, the current recycling infrastructure cannot handle this resin. Even if the resin is technically capable of being recycled, the claim is deceptive since it asserts an environmental benefit where no significant or meaningful benefit exists.
4. Comparative claims must be stated in a way that makes the basis for comparison as clear as possible. The comparison should also be substantiated.
• Example: You want to promote the fact that your production process produces 25% fewer greenhouse gas (GHG) emissions than competitive processes. You must be able to state the specific GHG levels for your process and all of your competitors, and ensure that the competitive data is both accurate and current. Based upon FTC general regulations and its guidelines relating to advertising claims and substantiation, and the environmental guidelines developed by the FTC either singly or jointly with the EPA, all marketing and sales materials should
meet the following criteria:
IV. ENVIRONMENTAL-SPECIFIC CLAIMS
A. General
Unless substantiation can be provided, broad environmental claims must either be avoided or qualified. Further, claims must not create broader positive impressions than what is communicated by the specific claim.
• Example: Naming or describing a product as “Eco-Friend” would be deceptive if it leads to the belief that the product has environmental benefits which you cannot substantiate. However, the claim would not be deceptive if "Eco-Friend" were followed by clear and prominent qualifying language limiting the positive representation to a particular product attribute that could be substantiated, providing that no other deceptive implications were created by the context.
Note that the same standards hold true for any graphic seal, design or icon designed to communicate positive environmental attributes or benefits. Each must be accompanied by prominent qualifying language limiting the positive representation to a particular product attribute that could be substantiated, providing that no other deceptive implications were created by the context.
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• Example: A product is labeled “environmentally preferable.” This claim is qualified
by stating that it “contains no harmful VOCs.” However, if the production or use of
the product creates any other harmful emissions, the claim is deceptive, as it can be
interpreted in a broader context than what is specifically described.
B. Recyclability
A product or package should not be marketed as recyclable unless it can be
collected, separated or otherwise recovered from the solid waste stream for reuse,
or in the manufacture or assembly of another package or product, through an
established recycling program. However, unqualified claims of recyclability for a
product or package may be made if the entire product or package, excluding minor
incidental components, is recyclable.
To further avoid the potential for deception:
1. If a product or package is made of both recyclable and non-recyclable
components, the recyclable claim should be adequately qualified to clearly
state which portions or components are recyclable.
2. Claims of recyclability should be qualified to the extent necessary to avoid
consumer deception about any limited availability of recycling programs
and collection sites.
• Example: A nationally marketed 8 oz. plastic cottage-cheese container displays
the Society of the Plastics Industry (SPI) code (which consists of a design of
arrows in a triangular shape containing a number and abbreviation identifying the
component plastic resin) on the front label of the container, in close proximity to
the product name and logo. The manufacturer's conspicuous use of the SPI code
in this manner constitutes a recyclability claim.
Unless recycling facilities for this container are available to a substantial majority
of consumers or communities, the claim should be qualified to disclose the
limited availability of recycling programs for the container. If the SPI code,
without more, had been placed in an inconspicuous location on the container
(e.g., embedded in the bottom of the container) it would not constitute a claim of
recyclability.
Note from this example, taken directly from FTC documents, how
important it is for marketers of plastics used in packaging to understand the
guidelines: The FTC considers the “chasing arrows” symbols to be
potentially deceptive to consumers if not handled in the manner described.
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If recycling is not widely or generally available, claims should be qualified
to indicate the limited availability of programs. Two examples are “This
container may not be recyclable in your area,” or “Recycling programs for
this container may not exist in your area.” Other examples of adequate
qualification of the claim include providing the number of communities
with programs, or the percentage of communities or the population to
which programs are available.
3. No incidental components should be present that significantly limit the
ability to recycle a product or package. For example, if labeling
significantly reduces recyclability of a package, it would be deceptive to
refer to the package as recyclable.
4. A product or package that is made from recyclable material, but is not
accepted in recycling programs for such material, should not be marketed
as recyclable. In such a situation, it would be appropriate to communicate
that “This package contains 20% recycled material” but it would be
deceptive to state that the package can (once again) be recycled.
C. Recycled Content
A recycled content claim may be made only for materials that have
been recovered or otherwise diverted from the solid waste stream, either during
the manufacturing process (pre-consumer), or after consumer use (postconsumer).
Specific conditions include:
1. To the extent the source of recycled content includes pre-consumer
material, the manufacturer or advertiser must be able to substantiate that
the pre-consumer material would otherwise have entered the solid waste
stream. This is particularly important for plastics molders, fabricators and
processors:
• Example: A molder routinely collects spilled resin and scraps left over from the
original manufacturing process. After a minimal amount of reprocessing, the molder
combines the spills and scraps with virgin material for use in further production of
the same product. A claim that the product contains recycled material is deceptive
because the spills and scraps to which the claim refers are normally reused by
industry within the original manufacturing process, and would not normally have
entered the waste stream.
2. In asserting a recycled content claim, distinctions may be made between
pre-consumer and post-consumer materials. Where such distinctions are
asserted, any express or implied claim about the specific pre-consumer or
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post-consumer content of a product or package must be substantiated.
3. For products or packages that are only partially made of recycled material,
a recycled claim should be adequately qualified to avoid deception about
the amount, by weight, of recycled content in the finished product or
package.
• Example: A “juice box” (aseptic package) is made from layers of foil, plastic,
and paper laminated together. The label claims that “one of the three layers of
this package is made of recycled plastic.” The plastic layer is made entirely of
recycled plastic. The claim is not deceptive provided the recycled plastic layer
constitutes a significant component of the entire package.
D. Biodegradation
Claims of degradability should be qualified “by competent and reliable scientific
evidence” to avoid consumer deception about (1) the product or package’s ability
to completely break down into elements found in nature, (2) in the environment
where it is customarily disposed, and (3) the rate and extent of degradation.
Unless otherwise specified, a product must biodegrade or photodegrade in the
environment in which it is usually disposed (e.g., a sanitary landfill), and must do
so at a reasonably fast rate. Unless clearly stated, degradation must also be
complete, with no leftover synthetic or complex byproducts or residue.
• Example: According to the law, paper cannot be described as simply “biodegradable”, as
it will not break down in its typical disposal environment, a landfill, at a reasonably fast
rate. Technically, a paper product which claims to be biodegradable should qualify this
statement by including a statement such as: “When composted in a facility designed to
handle this type of paper, usually an industrial composting facility.”
However, clearly stating an exception to an unqualified claim can legitimize the
claim and remove the potential for deception:
• Example: Loop carriers are described as “Photodegradable” and qualified with the
phrase "Will break down into small pieces if left uncovered in sunlight." The claim is
supported by competent and reliable scientific evidence that the product will break down
in a reasonably short period of time after being exposed to sunlight and into sufficiently
small pieces to become part of the soil. Because the claim is qualified to indicate the
limited extent of breakdown, the manufacturer does not have to meet the elements for an
unqualified photodegradable claim, i.e., that the product will not only break down, but
also will decompose into elements found in nature.
Environmental Marketing Guidelines Page 7
1/07/09
E. Composting
A compostability claim must be substantiated by “competent and reliable scientific
evidence” that all the materials in the product or package will (1) break down
into, or otherwise become part of, usable compost (e.g., soil-conditioners, mulch,
(2) in a safe and timely manner, (3) in an appropriate composting program or
facility, or in a home compost pile or device. Claims must be substantiated, and
will be considered deceptive if:
1. Composting cannot occur in a home compost pile or device, and/or it is not
revealed that composting must occur in municipal or institutional facilities
and that the availability of these facilities is limited.
2. Consumers are misled into believing that landfilling will produce results
similar or equal to backyard composting,
3. The results of composting are not 100% usable as conditioners or mulch.
• Example: The description of a corn-based plastic as compostable (and/or
biodegradable) is deceptive if it is not clearly stated that products made from this
plastic must be composted in an institutional facility, and that the availability of
such facilities is limited.
However, limiting the sale of products to areas in which they can be composted, or
stating specifically where they can be composted, is acceptable and not considered
deceptive. In the example just mentioned, a description such as “Compostable
only in the area where this product or package was purchased” or “Compostable in
Northern Oregon” would typically not be considered deceptive.
F. Source Reduction
Source reduction claims should be qualified to the extent necessary to avoid
consumer deception about both the amount of reduction and the basis for any
comparison that is asserted. It is perfectly fine to say “This package creates 10% less
waste than our previous package.” However, simply stating “This package creates 10%
less waste” is ambiguous, and open to being considered deceptive.
Environmental Marketing Guidelines Page 8
1/07/09
V. IT’S BETTER TO BE SAFE…
As you can see, the laws are clear regarding the need for environmental claims to
be specific and substantiated. However, please keep these points in mind:
1. Whether a claim is specific enough, or provides proper substantiation, is
open to interpretation.
2. The FTC staff routinely issues new interpretations of the law. These may
complement or conflict with previous interpretations, including those
included here.
3. As an active participant in the development of communications materials,
it may be hard for you to be completely objective when it comes to
evaluating the legality of proposed environmental marketing claims.
4. This document was written from a U.S. perspective, but it is fairly safe to
assume that the FTC philosophy of specificity and substantiation is valid
globally. However, if marketing products outside of the United States,
please check the appropriate statutes and regulations for that region. This
is especially important in Europe, where product comparison claims are
either outlawed outright or considered to be a form of unfair competition.
5. Finally, please remember that the potential financial and perceptual costs
of making a mistake regarding environmental claims are high. Consult with
your Legal and Environmental Affairs Departments before making public
any environmental claim.
Robert Lilienfeld, Editor
FOOTNOTES
i Environmental Marketing Claims: Message to Vendors from the EPA and the Federal Trade Commission
(FTC), EPA-744-F-97-005, June 1997.
ii FTC, Part 260, Guides for the Use of Environmental Marketing Claims.
http://www.use-less-stuff.com/Environmental-Marketing-Guidelines.pdf
Environmental Marketing Guidelines
Prepared By Robert M. Lilienfeld, Editor
The Use Less Stuff Report
I. INTRODUCTION
The marketplace increasingly demands products that deliver high levels of functionality with reduced levels of environmental impact. Businesses are looking for ways to meet these demands, and in so doing must effectively communicate both the functional and environmental benefits of their offerings.
On the functional side, strong companies usually have a history of providing customers with data that support their product claims. Over time, this has become increasingly easier to do, as customers today are quite knowledgeable about the information needed to make decisions.
The environmental side is quite different, as benefits such as “more sustainable,” “greener,” and “eco-friendly” cannot be assigned numerical values, since they are qualitative in nature. Also, as of yet there are no agreed-upon mechanisms or third party organizations that can evaluate these types of claims or enforce protocols, methodologies, and use of terms. Significantly, environmental claims are different in a third way. Unlike functional benefits, which become a tangible part of your customers’ products, environmental benefits have the potential to be communicated by your customers as part of the marketing message to their customers. This means that companies must work hard to meet regulations and legislation designed to protect “consumers” at all levels.
II. THE BASICS
The key body of U.S. law and regulations governing marketing communications is The Federal Trade Commission Act of 1914, which established its namesake, the FTC. Section 5 of the Act prohibits “unfair methods of competition” and was amended in 1938 to also prohibit “unfair or deceptive acts or practices.” A representation, omission, or practice is deceptive if: (1) it is likely to mislead consumers acting reasonably under the circumstances; and (2) it is likely to affect
consumers’ conduct or decisions with respect to the product at issue.
Environmental Marketing Guidelines Page 2
1/07/09
Further, the FTC works jointly with the Environmental Protection Agency (EPA) to ensure that an organization’s environmental claims meet legal requirements. The EPA is as concerned about business-to-business activities as it is about business-to-consumer communications, as its literature regarding “deception” specifically calls out advertising, labeling, catalogs and sales presentationsi.
III. THE BIG PICTURE
Listed below are the four areas that are of most concern to the FTC regarding advertising claims of all types, but specifically those relating to the environment. Please keep in mind that the FTC makes it clear that you must comply with all of these concerns, not just those you feel are most advantageous or especially relevant to your product or message:
1. The single most important point to remember when making claims is to be as specific as possible. Doing so will require that claims be substantiated by communicating all of the following:
• What is being claimed -- Reduced energy consumption during production
• By how much -- By 12%
• Compared to what -- Versus the previous product formulation
Claims that are general or vague are not only considered to be meaningless, the FTC considers them to be deceptive. Technically, this means that claims which appear to be simple and harmless, such as “eco-friendly” and “green,” are actually open to scrutiny and legal action at the federal level. Such action can occur when the FTC is made aware of claims, either by their reviewing your materials or, more likely, via complaints from competitors, special interest
groups, state attorneys general, etc.
2. To further prevent deception, any qualifications or disclosures relating to your claims should be clear, prominent and easily understood. According to the FTC, “Clarity of language, relative type size and proximity to the claim being qualified, and an absence of contrary claims that could undercut effectiveness, will maximize the likelihood that the qualifications and disclosures are
appropriately clear and prominent.” ii
3. Environmental claims, attributes and benefits should not be explicitly or implicitly overstated. This requires that both the absolute and relative merits of a claim be considered.
Environmental Marketing Guidelines Page 3
1/07/09
• Example: Claiming that a package has been reduced in weight by 50% would be considered deceptive by the FTC if the package in question now weighed 1 gram, versus 2 grams in the past. However, a 50% move from 16 oz. to 8 oz. would probably be considered acceptable, based upon the absolute change in question.
• Example: A resin is described simply as being “recyclable.” However, the current recycling infrastructure cannot handle this resin. Even if the resin is technically capable of being recycled, the claim is deceptive since it asserts an environmental benefit where no significant or meaningful benefit exists.
4. Comparative claims must be stated in a way that makes the basis for comparison as clear as possible. The comparison should also be substantiated.
• Example: You want to promote the fact that your production process produces 25% fewer greenhouse gas (GHG) emissions than competitive processes. You must be able to state the specific GHG levels for your process and all of your competitors, and ensure that the competitive data is both accurate and current. Based upon FTC general regulations and its guidelines relating to advertising claims and substantiation, and the environmental guidelines developed by the FTC either singly or jointly with the EPA, all marketing and sales materials should
meet the following criteria:
IV. ENVIRONMENTAL-SPECIFIC CLAIMS
A. General
Unless substantiation can be provided, broad environmental claims must either be avoided or qualified. Further, claims must not create broader positive impressions than what is communicated by the specific claim.
• Example: Naming or describing a product as “Eco-Friend” would be deceptive if it leads to the belief that the product has environmental benefits which you cannot substantiate. However, the claim would not be deceptive if "Eco-Friend" were followed by clear and prominent qualifying language limiting the positive representation to a particular product attribute that could be substantiated, providing that no other deceptive implications were created by the context.
Note that the same standards hold true for any graphic seal, design or icon designed to communicate positive environmental attributes or benefits. Each must be accompanied by prominent qualifying language limiting the positive representation to a particular product attribute that could be substantiated, providing that no other deceptive implications were created by the context.
Environmental Marketing Guidelines Page 4
1/07/09
• Example: A product is labeled “environmentally preferable.” This claim is qualified
by stating that it “contains no harmful VOCs.” However, if the production or use of
the product creates any other harmful emissions, the claim is deceptive, as it can be
interpreted in a broader context than what is specifically described.
B. Recyclability
A product or package should not be marketed as recyclable unless it can be
collected, separated or otherwise recovered from the solid waste stream for reuse,
or in the manufacture or assembly of another package or product, through an
established recycling program. However, unqualified claims of recyclability for a
product or package may be made if the entire product or package, excluding minor
incidental components, is recyclable.
To further avoid the potential for deception:
1. If a product or package is made of both recyclable and non-recyclable
components, the recyclable claim should be adequately qualified to clearly
state which portions or components are recyclable.
2. Claims of recyclability should be qualified to the extent necessary to avoid
consumer deception about any limited availability of recycling programs
and collection sites.
• Example: A nationally marketed 8 oz. plastic cottage-cheese container displays
the Society of the Plastics Industry (SPI) code (which consists of a design of
arrows in a triangular shape containing a number and abbreviation identifying the
component plastic resin) on the front label of the container, in close proximity to
the product name and logo. The manufacturer's conspicuous use of the SPI code
in this manner constitutes a recyclability claim.
Unless recycling facilities for this container are available to a substantial majority
of consumers or communities, the claim should be qualified to disclose the
limited availability of recycling programs for the container. If the SPI code,
without more, had been placed in an inconspicuous location on the container
(e.g., embedded in the bottom of the container) it would not constitute a claim of
recyclability.
Note from this example, taken directly from FTC documents, how
important it is for marketers of plastics used in packaging to understand the
guidelines: The FTC considers the “chasing arrows” symbols to be
potentially deceptive to consumers if not handled in the manner described.
Environmental Marketing Guidelines Page 5
1/07/09
If recycling is not widely or generally available, claims should be qualified
to indicate the limited availability of programs. Two examples are “This
container may not be recyclable in your area,” or “Recycling programs for
this container may not exist in your area.” Other examples of adequate
qualification of the claim include providing the number of communities
with programs, or the percentage of communities or the population to
which programs are available.
3. No incidental components should be present that significantly limit the
ability to recycle a product or package. For example, if labeling
significantly reduces recyclability of a package, it would be deceptive to
refer to the package as recyclable.
4. A product or package that is made from recyclable material, but is not
accepted in recycling programs for such material, should not be marketed
as recyclable. In such a situation, it would be appropriate to communicate
that “This package contains 20% recycled material” but it would be
deceptive to state that the package can (once again) be recycled.
C. Recycled Content
A recycled content claim may be made only for materials that have
been recovered or otherwise diverted from the solid waste stream, either during
the manufacturing process (pre-consumer), or after consumer use (postconsumer).
Specific conditions include:
1. To the extent the source of recycled content includes pre-consumer
material, the manufacturer or advertiser must be able to substantiate that
the pre-consumer material would otherwise have entered the solid waste
stream. This is particularly important for plastics molders, fabricators and
processors:
• Example: A molder routinely collects spilled resin and scraps left over from the
original manufacturing process. After a minimal amount of reprocessing, the molder
combines the spills and scraps with virgin material for use in further production of
the same product. A claim that the product contains recycled material is deceptive
because the spills and scraps to which the claim refers are normally reused by
industry within the original manufacturing process, and would not normally have
entered the waste stream.
2. In asserting a recycled content claim, distinctions may be made between
pre-consumer and post-consumer materials. Where such distinctions are
asserted, any express or implied claim about the specific pre-consumer or
Environmental Marketing Guidelines Page 6
1/07/09
post-consumer content of a product or package must be substantiated.
3. For products or packages that are only partially made of recycled material,
a recycled claim should be adequately qualified to avoid deception about
the amount, by weight, of recycled content in the finished product or
package.
• Example: A “juice box” (aseptic package) is made from layers of foil, plastic,
and paper laminated together. The label claims that “one of the three layers of
this package is made of recycled plastic.” The plastic layer is made entirely of
recycled plastic. The claim is not deceptive provided the recycled plastic layer
constitutes a significant component of the entire package.
D. Biodegradation
Claims of degradability should be qualified “by competent and reliable scientific
evidence” to avoid consumer deception about (1) the product or package’s ability
to completely break down into elements found in nature, (2) in the environment
where it is customarily disposed, and (3) the rate and extent of degradation.
Unless otherwise specified, a product must biodegrade or photodegrade in the
environment in which it is usually disposed (e.g., a sanitary landfill), and must do
so at a reasonably fast rate. Unless clearly stated, degradation must also be
complete, with no leftover synthetic or complex byproducts or residue.
• Example: According to the law, paper cannot be described as simply “biodegradable”, as
it will not break down in its typical disposal environment, a landfill, at a reasonably fast
rate. Technically, a paper product which claims to be biodegradable should qualify this
statement by including a statement such as: “When composted in a facility designed to
handle this type of paper, usually an industrial composting facility.”
However, clearly stating an exception to an unqualified claim can legitimize the
claim and remove the potential for deception:
• Example: Loop carriers are described as “Photodegradable” and qualified with the
phrase "Will break down into small pieces if left uncovered in sunlight." The claim is
supported by competent and reliable scientific evidence that the product will break down
in a reasonably short period of time after being exposed to sunlight and into sufficiently
small pieces to become part of the soil. Because the claim is qualified to indicate the
limited extent of breakdown, the manufacturer does not have to meet the elements for an
unqualified photodegradable claim, i.e., that the product will not only break down, but
also will decompose into elements found in nature.
Environmental Marketing Guidelines Page 7
1/07/09
E. Composting
A compostability claim must be substantiated by “competent and reliable scientific
evidence” that all the materials in the product or package will (1) break down
into, or otherwise become part of, usable compost (e.g., soil-conditioners, mulch,
(2) in a safe and timely manner, (3) in an appropriate composting program or
facility, or in a home compost pile or device. Claims must be substantiated, and
will be considered deceptive if:
1. Composting cannot occur in a home compost pile or device, and/or it is not
revealed that composting must occur in municipal or institutional facilities
and that the availability of these facilities is limited.
2. Consumers are misled into believing that landfilling will produce results
similar or equal to backyard composting,
3. The results of composting are not 100% usable as conditioners or mulch.
• Example: The description of a corn-based plastic as compostable (and/or
biodegradable) is deceptive if it is not clearly stated that products made from this
plastic must be composted in an institutional facility, and that the availability of
such facilities is limited.
However, limiting the sale of products to areas in which they can be composted, or
stating specifically where they can be composted, is acceptable and not considered
deceptive. In the example just mentioned, a description such as “Compostable
only in the area where this product or package was purchased” or “Compostable in
Northern Oregon” would typically not be considered deceptive.
F. Source Reduction
Source reduction claims should be qualified to the extent necessary to avoid
consumer deception about both the amount of reduction and the basis for any
comparison that is asserted. It is perfectly fine to say “This package creates 10% less
waste than our previous package.” However, simply stating “This package creates 10%
less waste” is ambiguous, and open to being considered deceptive.
Environmental Marketing Guidelines Page 8
1/07/09
V. IT’S BETTER TO BE SAFE…
As you can see, the laws are clear regarding the need for environmental claims to
be specific and substantiated. However, please keep these points in mind:
1. Whether a claim is specific enough, or provides proper substantiation, is
open to interpretation.
2. The FTC staff routinely issues new interpretations of the law. These may
complement or conflict with previous interpretations, including those
included here.
3. As an active participant in the development of communications materials,
it may be hard for you to be completely objective when it comes to
evaluating the legality of proposed environmental marketing claims.
4. This document was written from a U.S. perspective, but it is fairly safe to
assume that the FTC philosophy of specificity and substantiation is valid
globally. However, if marketing products outside of the United States,
please check the appropriate statutes and regulations for that region. This
is especially important in Europe, where product comparison claims are
either outlawed outright or considered to be a form of unfair competition.
5. Finally, please remember that the potential financial and perceptual costs
of making a mistake regarding environmental claims are high. Consult with
your Legal and Environmental Affairs Departments before making public
any environmental claim.
Robert Lilienfeld, Editor
FOOTNOTES
i Environmental Marketing Claims: Message to Vendors from the EPA and the Federal Trade Commission
(FTC), EPA-744-F-97-005, June 1997.
ii FTC, Part 260, Guides for the Use of Environmental Marketing Claims.
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