Comment Deadline Set on FTC Updates to "Green Guides"

Comments on FTC's Guides for the Use of Environmental Marketing Claims ("Green Guides") are due by February 21, 2023. The Notice was published in the Federal Register.

As previously covered, the Green Guides lay out principles to help users avoid potentially deceptive environmental advertising and labeling claims under FTC Act Section 5 ("Unfair methods of competition unlawful; prevention by Commission"). FTC said that it proposed updates to the Green Guides in light of the increased interest in environmentally friendly products. The RFC posed questions about environmental claims in general but also on specific environmental topics, including (i) carbon offsets and climate change, (ii) whether packing or products are "compostable," degradable, ozone-friendly, recyclable, organic or sustainable, (iii) whether the product contains "recycled content" and (iv) the energy efficiency of the product.