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.

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