AHPA on Green Guides: Sometimes General Claims Okay

The American Herbal Products Association (AHPA; Silver Spring, MD) has submitted its comments on FTC’s proposed changes to its Green Guides covering the use of environmental marketing claims. Among its comments, AHPA suggested there might be some instances for which a general claim like “environmentally friendly” may be suitable and not deceptive.

Part of the FTC’s goals in revising its guidelines, last updated in 1998, is to take into consideration new environmental claims and developments that have sprung up over the past decade. One of the agency’s concerns is that a growing use of “green” claims in the market has resulted in an abuse and misuse of general claims such as “eco-friendly” and says that companies “should not make unqualified general environmental benefit claims.”

As part of its reasoning why general claims might sometimes be okay, AHPA provided the example of an eco-friendly farm that complies with USDA’s National Organic Program, produces its energy through wind or solar power or by purchasing carbon offsets, and uses only recycled packaging or delivers produce unpackaged. In this case, the association argued, the term “eco-friendly” would be very appropriate.

AHPA also provided other comments regarding carbon offsets, recyclable materials, compostable claims, and organic claims for non-agricultural products.

Click here to read AHPA’s comments in full.

Click here to read FTC's proposed Green Guides changes.