The Upcoming Revised FTC Guidelines on Greenwashing Need to Differentiate Between Post-Industrial and Post-Consumer Plastics

New Greenwash guidelines are being reviewed and updated by the FTC. Comments are due by 12/10/2010. We’re looking to you as a consumer to look at some of our issues on how some of the guidelines are being revised or created. As a sample, did you know a FTC study on Unqualified Claims has determined that:

      59% of public thinks “green” means recyclable

      61% of public thinks “green’ means recycled content

      53% think “green” means biodegradable


  • o    57% think recyclable
  • o    56% think recycled content
  • o    55% biodegradable
  • o    51% renewable materials

Please visit the site before 12/10/2010 to make any comments, additions or clarifications. The complete document with rules for making comments can be found at For a summary of the revision proposals, please see These guidelines provide an opportunity to make sure that beyond just making product claims, we can steer behavior to a more sustainable culture of reducing, reusing and recycling our produced materials.

 One key area to address is defining the difference between post-industrial plastics and post-consumer plastics and why the differentiation needs to be made for these updates.

 Right now, in the summary, the new guideline is stated as follows:

Made with Renewable Materials

• Marketers should qualify claims with specific information about the renewable material (what it is; how it is sourced; why it is renewable).

 Let’s define the difference:

  • ·         Post-consumer plastic has been used for its intended use at least once. Another key distinction is having left the manufacturing facility.
  • ·         Post-industrial plastics are scrap in the manufacturing process that has been looped back into the same manufacturing stream, not having left the manufacturing facility. While it is laudable that materials are not going to waste, the manufacturer would have done this anyway, unless they were irrational. From our perspective, calling post-industrial plastics as renewable or as post-consumer would be a mockery of green efforts.


Therefore, we want to make sure the guideline language reflects this distinction.

The new guideline is needed, but they still require context by the affected marketers to make sure the right message is conveyed. The maker of the post-industrial plastics can make a positive claim on the green value of their product, but be misleading to its buyers with savings that already occur, possibly diluting the positive benefits of recycling and green messaging.

 Don’t forget to provide your comments on the updates and additions by 12/10/2010 at

 FTC is not addressing bio-based polymers, but we will put our thoughts out on this topic and others in a future blog for your consideration before 12/10/2010.

 We welcome any other topics you wish to see or your comments on our posts.


Need more information? Envision Plastics Vice President, Tamsin Ettefagh will be happy to discuss your comments or concerns in greater depth. Contact her at 336/342-4749 Ext 225.


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