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What Do Marketers Need to Know About the Updated FTC Green Guides?

“Green marketing” expert Jacquie Ottman is the co-author (with David Mallen) of a report published in September through Ad Age called, How To Make Credible Green Marketing Claims: What Marketers Need to Know About the Updated FTC Green Guides. We spoke with her recently about the report and the challenges and continued evolution of making sustainability claims in marketing.

What prompted you to put together your 'Guide to the Green Guides'?

The FTC issued updates to the "Green Guides for Environmental Marketing Terms" in October 2012. These were the first updates since 1998, so much had changed in the marketplace. The research report that I co-authored with David Mallen (at the time still with the NAD, the industry's self-regulatory body), is intended as an essential resource written in layman's terms for marketers who need to understand what's new since the Guides were last updated – but for many readers, simply a guide to Green Guides and how they can be used to prevent misleading consumers about the validity of various sustainability claims, images and eco-labels.

How can companies benefit benefit from your guide?

How to synergize the work of your sustainability and marketing teams

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No one wants to mislead their consumers. Because making green claims is very challenging due to the technical nature of “green” and the fact that not all players — the marketers, the lawyers, the scientists or the FTC — really understand a lot of the science involved, risks of misleading consumers even among the most well-intended marketers is very high. Greenwashing can be an expensive and risky proposition: There's legal, financial, reputational and revenue risks that can result from lawsuits. A poll of consumers found that 78 percent would boycott products if they found they were associated with greenwashing. Our report talks about how to avoid these risks. I even included for the first time a 43-item checklist that businesses can follow to reduce the risks.

As a veteran in the field of "green marketing," how do you feel about the use/overuse of terms such as "green" and "sustainable"?

So expect not to see such terms used much in the future (and of course, if you do, be suspect!) Ditto for images like what I call the 'planets, babies and daisies.' The FTC declined to define "sustainable" in this round of Green Guides. I suspect it's for a couple of reasons: Sustainable is often equated with renewable (at least in the dictionary), and the FTC did provide guidance on “renewable.” However, we all in the business define “sustainable” in terms of the triple bottom line of environment, economy and equity. The Green Guides only cover environmental terms, so it is possible that they saw the term “sustainable” as out of there purview. Interestingly, the FTC declined not to define the term “natural” either. I suspect that's because natural is more often associated with health than environmental matters, so that's out of the purview of the Green Guides as well.

Do you feel we need to expand our vocabulary, or is the new familiarity of these terms necessary to continue to drive consumer engagement?

I think the problem may be just the opposite! There may be too many terms floating around and it's confusing consumers. For example, research that the FTC did as part of their process for updating the Guides showed that consumers confuse the term “renewable” with “recycled,” “recyclable” and “biodegradable.” What's important to remember is that marketers are responsible for what consumers take away from your messages, and that could be very different from what you intended. So in using these terms advertisers need to be very careful to test new communication and provide any additional clarification so that consumers take away the intended message.

What's the most important thing that marketers can learn from the FTC Green Guides?

Be specific. In lieu of using what is called 'generalized environmental claims' such as “green” and "eco-friendly," simply state the specific environmental benefit of your product. Examples might include “energy efficient,” "made with 25% recycled content" and "fuel efficient.”


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