Sometimes, I don’t know my own strength. The day after my Graph Expopresentation about Greenwashing, the FTC released its long-awaited Green Guides revision draft for public comment. The documents are available for download here, and the 60-day public-comment period is open through December 10, 2010. The thrust of these new guidelines is to clear the air of the clutter and obfuscation that has permeated the world of green claims for, lo, these many years. Following are a couple of examples cited in the FTC’s press release:

"The revised Guides caution marketers not to make blanket, general claims that a product is “environmentally friendly” or “eco-friendly” because the FTC’s consumer perception study confirms that such claims are likely to suggest that the product has specific and far-reaching environmental benefits. Very few products, if any, have all the attributes consumers seem to perceive from such claims, making these claims nearly impossible to substantiate."

"The proposed Guides also caution marketers not to use unqualified certifications or seals of approval – those that do not specify the basis for the certification. The Guides more prominently state that unqualified product certifications and seals of approval likely constitute general environmental benefit claims, and they advise marketers that the qualifications they apply to certifications or seals should be clear, prominent, and specific."

This second example could significantly change the way we speak about certified products and forests. A statement such as “20% of (company’s) raw materials originate from sustainable forest management certified sources”could now be fair game for a challenge, as the language is overly broad and does not provide a substantive basis for the claim. The name(s) of the specific certification program(s) referenced would go a long way toward validating this claim, as would transparency as to whether this volume of certified resource is proprietary or purchased on the open market. All in all, the FTC’s proposed revision to the Green Guides seems like a major step forward. What the revised Guides may not prevent, however, are claims that fail the test of Honesty. As I pointed out to my Graph Expo audience, these green claims are true (or true, as far as they go), but are merely empty promises. A case in point is that of a paper merchant which, on its website, states that it is XYZ-certified. Fair enough. That is a true statement. Yet, for the life of me, I see no mention of XYZ-certification in the specifications of any of the paper that this merchant offers, leading me to believe that it does not actually sell any. As readers of this blog know, a Chain-of-Custody certification is really verification that a business has the ability to track and document the flow of certified material through its operation. There is nothing inherently “green” about a C-o-C. It is the certified fiber in the product that has the green pedigree. And  without XYZ-certified paper to sell, the merchant’s claim about being certified, though true, is empty. And that’s just greenpucky.