The Upcoming Revised FTC Guidelines on Greenwashing Need to be Clear and Flexible on Use of “Free of” Language

We are tardy in posting this but, new Greenwash guidelines are being reviewed and updated by the FTC. Comments were due by December 10. We’re looking to you as a consumer of HDPE to look at some of our issues on how some of the guidelines are being revised or created. 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 issue requires clear guidelines, yet poses an opportunity for confusion. The FTC prohibits claims of being “Free of” certain additives or ingredients if the product never contained those additives or ingredients. We wholeheartedly agree with this guideline with one small exception.

Currently, the general public has concerns with plastics containing BPA (Bisphenol A, is an organic compound with two phenol functional groups used to make polycarbonate plastic and epoxy resins, along with other applications. More information can be found at Since 2008, studies have indicated possible dangers to human health from ingestion of this compound. BPA is used as a coating in some plastics to provide a barrier to help preserve the container’s contents. The particular plastic resins that have used BPA are Type 3 (or PVC) or Type 7 (a catchall for all other plastics).

The problem for the HDPE (Type 2) producers is that BPA has never been used as a container barrier, because of its high density formulation not requiring it.

Unfortunately, most consumers of plastics products don’t make that discernment and think that all plastics have BPA, therefore making decisions based on that erroneous assumption.

The new guideline is needed, but the public still needs the proper context of the use of this barrier to make sure the right message is conveyed.

This is one example of where the guideline needs to have flexibility to inform and educate the public on the true aspects of a particular product and to allay fears the consumer may have.

Don’t forget to provide your comments on the updates and additions at:

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.

How is a USDA Ban on Imported Landfill Mined Recycling Costing American Jobs?

Recently, the USDA banned all landfill mined cardboard and plastics recycling from outside the US, except from Canada, Complete details on the ban can be found at The primary concern is potential contamination of the US food supply as this material is transported through the US to recycling processing centers. This ban was enacted October 2010 following the discovery of bacteria and insect-infested meat in a shipment of plastic scrap entering the U.S. from Mexico. Recently, the strict enforcement has created significant hardship to US processors.

While we don’t defend bringing potential contaminants into the US food supply, the ban needs to be structured differently to not halt commerce in this vital industry. The new regulations, when enforced strictly, have added significant cost to bringing in the materials, with no significant benefit to the health and safety of the American food supply. As a result, the materials are being sold by foreign suppliers to other countries with less stringent regulations, thereby causing a loss of jobs to American processors, because the American processors cannot get adequate supply within the US at competitive pricing.

These new regulations need to be moderated to fit the circumstances appropriately. In particular, as long as the materials have not been co-mingled with other potentially contaminated sources (per the ban) and are coming from documented and confirmed reliable sources, the rigidity required by the new ban is not necessary. These confirmed sources have always cleaned their product properly before shipping from their facilities.

Since the ban was enacted, it has been adjusted slightly for Canadian imports, as these sources have proven sanitized results. But we need to have this interpretation carried across to other NAFTA suppliers to the US, who have proven the same stringent standards on sanitized products.

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.

Is Getting Rid of Plastics Bags the Complete Solution?


We’re sure you are tired of seeing the plastic bag tumbleweeds along your highways, but is eliminating plastic bags all together the right answer or are there better options? In light of the recent ban on plastic bags in LA County,, we’d like to explore a few aspects of the issue.

3 Options Currently Available to Replace Plastic Bags Use

In lieu of plastic bags, these options are the most common:

  1. Paper bags
  2. Reusable bags
  3. Biodegradable bags


Let’s look at some of the known and potential problems with these options:

Paper bags

Paper bags have been offered as a replacement. While they use renewable resources as their base material, the energy used to produce them is almost double as plastic bags. They tear easier. Not too many shoppers like to see their purchases scattered all over the parking lot. They lose their strength if they get wet. If you carry meat packets in them, they may leak in your car. Also, if they get wet, they may not be acceptable for recycling.


On the plus side, they will eventually decompose in the landfills, if they are not recycled or reused.

Reusable bags

Reusable bags are best used for dry goods only. Reusable bags can be a source for cross contamination of food products possibly causing foodborne illnesses to propagate. Per the June 9, 2010 report “Assessment of the Potential for Cross Contamination of Food Products by Reusable Shopping Bags  “ by Charles P. Gerba, David Williams and Ryan G. Sinclair:

Most foodborne illnesses are believed to originate in the home. Reuse of bags creates an opportunity for cross contamination of foods. The purpose of this study was to assess the potential for cross contamination of food products from reusable bags used to carry groceries. Reusable bags were collected at random from consumers as they entered grocery stores in California and Arizona. In interviews it was found that reusable bags are seldom if ever washed and often used for multiple purposes. Large numbers of bacteria were found in almost all bags and coliform bacteria in half. Escherichia coli were identified in 12% of the bags and a wide range of enteric bacteria, including several opportunistic pathogens. When meat juices were added to bags and stored in the trunks of cars for two hours the number of bacteria increased 10-fold indicating the potential for bacterial growth in the bags. Hand or machine washing was found to reduce the bacteria in bags by >99.9%. These results indicate that reusable bags can play a significant role in the cross contamination of foods if not properly washed on a regular basis. It is recommended that the public needs to be educated about the proper care of reusable bags by printed instructions on the bags or through public service announcements.

This report can be found at

Biodegradable bags

Biodegradable bags are a great concept, but just break down into smaller particles of plastic bags or contaminate the recycling loop. Another potential impact is slowing down the progress made in recycling. If consumers aren’t sure whether to recycle or to allow to decompose, they will probably choose to dispose in the garbage, sending all plastic material to the landfill. We will discuss in greater detail in a future blog article about our position on biodegradable plastics and its impact on the recycling plastics stream.

Plastic Usage Must Be Reduced … But Let’s look at it Sensibly

We all want to get rid of the plastic bag tumbleweeds, but let’s not cause other problems with a total ban. Let’s be strategic about the reduction of plastic bag use and strengthen the recycling programs and processes to ensure a greater benefit. The true need is for better recycling processes, both for collection of the bags after use and for recycling the bags themselves.


Encourage the use of recyclable bags or boxes for purchases that can’t contaminate other purchases or provide a channel for health risks. Otherwise offer a plastic bag option for those items that can contaminate. There are uses for plastic bags as a barrier from contamination. And most grocery stores now have programs to collect your used plastic bags and recycle them.


A suggestion would be to rinse the bags from any residue and put them where you can remember them on your way to the store the next time. That way, you can deposit them in the recycling bins on your way in and help keep the loop closed.


On the plus side, recycling is going up and less is going to the landfill. The more we take advantage of recycling plastic, the less virgin plastic will be produced. In an ideal world, we could just recycle the plastic we have already produced and not need virgin plastic.


Please Don’t Rush to Judgment


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.