FTC Green Guidelines Help Prevent Greenwashing, Volume 4, Issue 5

FTC Green Guidelines Help Prevent Greenwashing

Volume 4, Issue 5

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Sustainable Efforts

Proposed FTC guidelines prevent ‘greenwashing’

Changes to the “Green Guides,” proposed by the Federal Trade Commission (FTC), Washington, DC, would help consumers evaluate environmental claims and provide assurances that claims are factual.

The proposed changes also are designed to make it easier for brand owners to understand and follow the guidance and avoid making misleading claims. “In recent years, businesses have increasingly used ‘green’ marketing to capture consumers’ attention and move Americans toward a more environmentally friendly future,” says FTC Chairman Jon Leibowitz. “But what companies think green claims mean and what consumers really understand are sometimes two different things. The proposed updates to the Green Guides will help businesses better align…product claims with consumer expectations,” he explains.

Environmental labeling missteps are common, according to Catherine Goodall, project director at Environmental Packaging International, Jamestown, RI, in a presentation at a Leadership Conference held in September 2010 by the Institute of Packaging Professionals (IoPP), Naperville, IL.

The Green Guides seek to prevent overstated, general environmental benefit claims; inappropriate claims related to recyclability, recycled content, degradability, reusability and compostability; misuse of the Mobius loop (chasing arrows symbol) or SPI resin code; and inappropriate comparative claims.

First issued in 1992 and revised in 1996 and 1998, the Guides describe

  • General principles that apply to all environmental marketing claims
  • How consumers are likely to interpret particular claims and how marketers can substantiate these claims
  • How marketers can qualify their claims to avoid deceiving consumers.

The revised Guides caution marketers to avoid blanket, general claims such as “environmentally friendly” because the FTC’s consumer perception study shows such claims are likely to suggest that the product has specific, far-reaching environmental benefits. However, few, if any products, have all the attributes consumers seem to anticipate from such claims, making them virtually impossible to substantiate.

For degradability claims, Goodall notes, “…the proposed changes clarify the ‘reasonable timeframe’ in which an item must degrade as being one year for solid items, and for compostability claims, ‘approximately the same time as the materials with which it is composted.’ They also explicitly state that unqualified degradable claims are deceptive if the item is typically disposed of in landfills, incinerators or recycling facilities.”

The proposed Guides also recommend avoiding unqualified certifications or seals of approval, describe how consumers understand terms such as “degradable,” “compostable” or “free of” a particular substance, and add guidance about claims related to “renewable” materials and energy, which have become common since the last revision of the guidance. Since the FTC’s research suggests consumers interpret claims like “renewable materials” differently than marketers intend, the revised Guides recommend providing specific information about the materials and energy used. In addition, marketers should not make unqualified renewable energy claims if the power used to manufacture any part of the product was derived from fossil fuels.

The proposed revisions also provide new guidance about carbon offset claims. Carbon offsets fund projects that reduce greenhouse gas emissions in one place in order to counterbalance emissions elsewhere. The Guides advise marketers to disclose if the emission reductions that are being offset by a consumer’s purchase will not occur within two years. They also advise marketers to avoid advertising an offset if the activity that produces the offset is already required by law.

The FTC is finalizing the revised Guides and will consider all public comments on the proposed changes that are received by December 10, 2010. Comments can be submitted electronically at https://ftcpublic.commentworks.com/ftc/revisedgreenguides. For more information, visit www.ftc.gov/os/fedreg/2010/october/101006greenguidesfrn.pdf, www.ftc.gov/os/2010/10/101006greenguidesproposal.pdf, www.enviro-pac.com.

Avoid Greenwashing by…

» Qualifying all claims

» Avoiding general claims* like Sustainable, Eco-friendly, Green, Natural, Environmentally safe
* Unless accompanied by qualifying information

» Using a “recyclable” claim only if a recycling infrastructure for the package is accessible to a substantial majority of consumers or communities. This number not quantified by the FTC, but is interpreted to be at least 60% of consumers or communities. The calculation involves reviewing both what is collected by communities and what is accepted by the recycling facilities.

» Accompanying any Mobius loop with qualifying text, i.e., “x% recycled content” or “recyclable.” Note: Under FTC Guidelines using a Mobius loop alone constitutes a claim that the packaging and product consist of 100% recycled materials and are universally recyclable.

» Using the SPI resin code consistent with SPI guidance and state laws (i.e., on the bottom of containers, not prominently or near environmental claims).

» Including percentages when claiming recycled content

» Substantiating any claims of degradability, biodegradability, photodegradability, compostability, oxo-biodegradability based on testing of the finished package/components rather than the material alone. Note: All of these claims are problematic if the packaging/product is typically disposed of in a landfill, since landfills are designed to prevent degradation.

» Qualifying compostability claims regarding type of composting facility and accessibility of municipal and institutional composting operations.

» Quantifying comparative claims, i.e., reduced landfill discards by 1.24 pounds.

Source: Update on Sustainable Packaging Requirements: EPR, Scorecard and Labeling, presented by Catherine Goodall of Environmental Packaging International at IoPP 2010 Leadership Conference, St. Louis, MO.


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TricorBraun donates packaging for shampoo to clean oily birds


Wayne Anstadt (left) of TricorBraun’s Los Angeles, operation, was instrumental in donating caps, bottles and cartons to Cardinal Laboratories, Azusa, CA, for specially formulated shampoo.

Cardinal, which is led by President Tony de Vos (right), delivered 2,000 gallons of the shampoo to Gulf Coast bird sanctuaries during the summer of 2010. Staff and volunteers used the shampoo to clean birds contaminated by the massive crude oil spill that occurred in the Gulf of Mexico after BP’s Deepwater Horizon drilling rig exploded on April 20, 2010. Oil flowed until the well was capped on July 15, 2010.

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Source Reduction

ISBM process produces PET containers with ‘handles’

An injection stretch blow molding (ISBM) process creates a grippable “handle” on polyethylene terephthalate (PET), high-density polyethylene, biaxially oriented polypropylene or polylactic acid bottles.


Developed by Procter & Gamble Co., Cincinnati, OH; Sidel, Le Havre, France; and PTI-Europe, Yverdon-les-Bains, Switzerland, a subsidiary of Plastic Technologies, Inc., Holland, OH; the Deep Grip™ technology enables significant grip depth (more than 25 millimeters (mm, 1-inch) on either side with an extremely thin (less than 0.3mm or 0.01-inch) grip “web” thickness. (The grip web is where the hole would be in conventional handled bottles.) Since the grip geometry also provides structural benefits, container weight can be reduced 20%-25%. Making the container and handle from the same material also eliminates downstream recycling issues and contributes to lightweighting objectives. In addition, ISBM offers higher output per cavity and mechanical benefits (better top/side load, drop and creep resistance) in a smaller equipment footprint versus extrusion blow molding, the process traditionally used to produce handled bottles.

Sidel equipment produces Deep Grip bottles in a two-step process that begins with conventional stretch blow molding followed by a proprietary handle-forming operation within the machine. Compatible with diameters up to 220mm (8.6 inches), the technology can produce containers that hold up to 6 liters (1.5 gallons). Designs can be further differentiated by handle location, grip diameter and profile. Target markets include detergents, household cleaners, noncarbonated beverages (juices, ready-to-drink teas, water, etc.), milk, edible oil, motor oil, dry products and baby bottles. For more information, visit www.sidel.com, www.plastictechnologies.com.

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Short-skirt closure debuts in U.S., Canada

Corvaglia, Eschlikon, Switzerland, a leader in short-skirt closure production, now offers its 26-millimeter CSN BTL cap in the United States and Canada.


The lighter short-skirt closure relies on a mechanical tamper-evident band and only leaks if the band has been removed completely. “We call this BTL, Break-Then-Leak,” says Romeo Corvaglia, chief executive officer of Corvaglia Holding AG. “Opening is extremely simple and safe, even for children and elderly people,” he adds.

Early adopters include Ice River Springs Water Co. Inc., Feversham, Ontario, Canada, and Silver Springs Bottled Water Co., Silver Springs, FL. The CSN BTL cap weighs 1 gram, 0.6 grams lighter than its predecessor, and the bottle neck finish was reduced to 1.75 grams from 3.15 grams. With an annual volume of more than 1 billion bottles and closures, this lightweighting saves more than 2,000 metric tons of resin and cuts energy consumption roughly in half. For more information, visit www.corvaglia.ch.

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Source-reduced containers contain recycled content

Diamond Weave polypropylene (PP) tubs and pails from Ropak Packaging, Fountain Valley, CA, contain up to 25% post-consumer content and 35% less resin without impacting stacking strength. A patent-pending process forms a diamond lattice structure on the inner surface of the container that enhances structural strength. “This lightweighting results in fewer greenhouse gas (GHG) emissions, less energy required to manufacture product and minimizes the generation of waste,” says Pansy Leo, marketing manager at Ropak.


Research by Packaging Knowledge Group LLC (PKG), Rochester, MI, confirms the Diamond Weave containers reduce GHG emissions up to 43% compared to predecessor containers. Cube utilization is 34% better too. PKG also reports Diamond Weave containers are recycled at levels above 50% and reuse is common. “Sustainability of packaging is becoming a primary goal for consumer packaged goods suppliers, packaging suppliers and product designers alike,” explains Leo. “But greenwashing can make it difficult for everyone to select and use the best possible packaging solutions for achieving sustainability. We are pleased to participate in the review process conducted by an independent expert on Greener Package Sustainability Guidelines to help the industry move toward better packaging sustainability.”

Diamond Weave Technology produces containers with capacities from 0.6 to 5.3 gallons in a variety of shapes and sizes – including square and rectangular. For more information, visit www.ropakcorp.com, www.packagingknowledgegroup.com.

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Biodegradable Materials

Oxo-biodegradable resin begins to move into closures

Oxo-biodegradable resin, which has been making some inroads in container applications, is now beginning to be seen in closures.

Norland International Inc., Lincoln, NE, claims the first oxo-biodegradable cap and is making it from a low-density polyethylene (LDPE)/oxo-biodegradable additive blend in three standard colors -- natural, earth green and blue. Dubbed Earth Cap, it’s being used by at least one Norland customer and features a biodegradable, non-adhesive, tamper-evident label and 2-millimeter foam seal for a totally biodegradable structure.

Designed for 5-gallon water bottles, the 55-millimeter Earth Cap offers a two-year shelf life, the same as traditional non-degradable alternatives. It also costs about the same as a non-degradable cap and is a drop-in replacement, so its adoption requires no changes on the packaging line.

A proprietary additive from Wells Plastics Ltd., Stone, UK, enhances degradability of the LDPE while maintaining its clarity and tensile strength. Once disposed of and exposed to ultraviolet light, heat and moisture, the Earth Cap embrittles and then breaks into small pieces. When the molecular weight is reduced sufficiently, the material becomes available for bio-digestion and the broken down matter becomes a food source for microbes. Depending on environmental conditions, the Earth Cap is expected to totally degrade in 5 to 10 years. According to research by Wells Plastics, the caps that contain the oxo-biodegradable additive will degrade in landfills, ditches, rivers and other water sources, but also are fully recyclable and do not contaminate the LDPE recycling stream. For more information, visit www.norlandintl.com, www.wellsplastics.com.

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Yogurt maker switches from PS to PLA for multipack cups

Stonyfield Farm, Londonderry, NH, has converted its multipack cups to corn-based polylactic acid (PLA). The PLA cups reportedly look and feel the same as the petroleum-based polystyrene (PS) cups they replace, but are stronger and reduce breakage.

Cups feature a “Made from Plants” stamp on the bottom and are thermoformed, filled and sealed at Stonyfield from PLA sheet produced by Clear Lam Packaging, Inc., Elk Grove Village, IL, using Ingeo PLA bio-resin from Natureworks LLC, Minnetonka, MN.

Currently, Stonyfield uses an offset program to produce a sustainably grown amount of corn equal to the amount used for the cups. However, within five years, the U.S. Department of Energy, Washington, DC, predicts that PLA will be derived from nonfood plants.

Like its PS predecessor, the PLA cup is not recyclable in most communities. But, “Even without a recycling option in the early stages, plant-based plastic is already better for the planet than PS because it produces lower carbon emissions and requires less fossil fuel to make,” states Nancy Hirshberg, vice president of Natural Resource at Stonyfield. “As this new type of plastic becomes commonplace, the potential environmental benefits only get better,” she predicts. Brands involved in the change include YoBaby, YoToddler and YoKids (as well as B-Healthy, B-Well, Probiotic & O’Soy). For more information, visit www.stonyfield.com/MadeFromPlants/, www.clearlam.com.

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Renewable Materials

P&G adopts sugar-cane-based HDPE

Procter & Gamble Co. (P&G), Cincinnati, OH, plans to convert its Pantene Pro-V, COVERGIRL and Max Factor brands to sugarcane-derived high-density polyethylene (HDPE) packaging. The company plans a two-year global pilot rollout with the first packs due on store shelves in 2011.

Braskem SA, São Paulo, Brazil, manufactures the HDPE using ethanol made from sustainably grown Brazilian sugarcane. The resulting containers are 100% recyclable in existing municipal recycling facilities. “This innovation is truly consumer-driven,” reports Gina Drosos, group president, Global P&G Beauty. “As we talk with women around the world, they tell us that they want to make themselves more beautiful without making their environment less beautiful,” she concludes.

The conversion to sugar-cane-based HDPE is part of the long-term environmental sustainability vision recently unveiled by P&G. Long-term, the company is committed to using 100% renewable or recycled materials for all products and packaging; sending zero consumer and manufacturing waste to landfills; powering its plants with 100% renewable energy; and designing products that maximize the conservation of resources. More immediate goals, to be achieved by 2020, include replacing one-fourth of petroleum-based materials with sustainably sourced, renewable materials, a 20% reduction in packaging, a study of ways to eliminate landfill disposal of consumer solid waste, conversion to renewable energy for 30% of power needs, plus reductions in manufacturing waste and truck transportation. For more information, visit www.pg.com, www.braskem.com.

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Recycling/Recycled Content

Package testing quantifies impact on PET recycling stream

Testing by Plastic Technologies, Inc., Holland, Ohio, quantifies the impact of polyethylene terephthalate (PET) containers (including resins, additives, adhesives, labels, etc.) on the recycling stream. The third-party testing program validates claims about recyclability.

“The current concern is that new materials entering the market may cause problems in the recycling stream, including increasing the yellowness and/or haze of recycled PET (rPET). This is why it is important to test various packaging components for recycling stream compatibility early in the development process,” says Frank Schloss, vice president, PTI.

Although use of new resins, additives and multilayer structures is increasing, little is known about what effect these materials have on recycled material. PTI is one of two U.S. companies approved by the Association of Postconsumer Plastic Recyclers (APR), Washington, DC, to provide testing services in conjunction with the organization’s guidance documents. The voluntary screening guidelines help brand owners and packaging suppliers understand the approximate effect their material or container might have on the quality of the rPET stream. “The only way for brand owners to really be able to claim that their package is fully recyclable and meets APR guidelines is to subject it to testing that can support their position,” he explains, adding, “The demand for rPET resin very often outstrips supply. When you look at what comprises the PET recycling stream today, it’s primarily soft drink and water bottles. When you broaden collection efforts to include shrink…labeled containers, plus vitamin water, juice, cosmetic and household chemical bottles, you…introduce complications that can lower the quality of the cleaned and washed rPET material.”

Testing options include quick and in-depth protocols. The preliminary quick test yields data about yellowing and hazing tendencies in less than two weeks. More in-depth critical guidance testing typically requires a month and analyzes material composition, as well as attributes such as color, haze, intrinsic viscosity, black specks, etc. for waste stream impact. End-use application studies extend the timeline another month. “The question that we all need to address is, ‘What is going to happen to that bottle when it is time to dispose of it?’” says Schloss. “Should the consumer include it with their recyclables? Can it be easily sorted using today’s manual and automated processes? Can it be turned into high quality rPET or will it contribute to the degradation of the recycled material supply? The answer to that lies in what decisions are made well before the raw material gets converted into a finished package,” he concludes. For more information, visit www.plastictechnologies.com, www.plasticsrecycling.org.

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Personal-care product line converts to 100% rPET bottles

The Hain Celestial Group Inc., Melville, NY, has converted its Avalon Organics personal-care product line to 100% post-consumer-recycled (PCR) polyethylene terephthalate (rPET) bottles from Amcor Rigid Plastics, Manchester, MI.

The conversion from 100% virgin resin to 100% PCR resin is a first for Hain Celestial’s personal-care division and involves 11-ounce flask (oval) bottles for shampoo and conditioner and 12-ounce bullet (round) containers for hand soap, bath and shower gel, and hand and body lotion. The switch to rPET delivers major sustainability benefits:

* Shrinks carbon footprint 46%, an annual reduction of about 258,000
kilograms of carbon dioxide emissions, while energy consumption
declines 71%

* Diverts nearly 4 million PET bottles from landfills each year

“Due to slight modifications in bottle configuration and without adding weight, Amcor was able to deliver greater bottle performance with a more rigid and robust container that was easier to fill and label,” reports Manuel Mosqueda, senior manager, Packaging Engineering for Hain Celestial.

Sourcing bottles from Amcor’s manufacturing facility in Commerce, CA, also positively impacts costs, energy consumption and carbon footprint compared to the virgin containers, which were purchased from a Canadian distributor. Amcor recently added PCR capability at the California operation and produces containers with varying percentages of recycled content for other customers. Unlike other PET container makers, Amcor is vertically integrated for PCR products and has a reliable source of food- and nonfood-grade rPET. Hain Celestial plans to convert other personal-care products to 100% rPET containers, including the Alba Botanica Hawaiian shampoo line. For more information, www.amcor.com.

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Recycled-content paperboard helps meet ‘green’ goals

Knightkote Matte Packaging and Folding Board from SMART Papers, Hamilton, Ohio, contains 50% recycled content (40% derived from post-consumer waste (PCW) and 10% from post-industrial waste). Options include coated one side and coated two sides with a 92 brightness reading in calipers ranging from 7 to 14 points. The paperboards also offer superior print fidelity and are engineered to handle foil stamping, folding, scoring, aqueous coating, varnish, embossing and die-cutting.

“The vast majority of premium coated board products contain no PCW fibers,” says Tom Kleimeyer, director of Marketing for SMART papers, noting, “Forty percent PCW is a significant new benchmark in this high-visibility, high-demand category of printing and converting papers.” All pulp used to make Knightkote paperboard is certified by one or more of the following organizations: Forest Stewardship Council U.S., Minneapolis, MN; the Sustainable Forestry Initiative, Inc., Washington, DC; the Programme for the Endorsement of Forest Certification International, Geneva, Switzerland. Mohawk Fine Papers serves as the exclusive dealer and marketer of SMART Papers’ products. For more information, visit www.mohawkconnects.com.

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LCA shows recycling offsets CO 2 burden of glass

Recycled content offsets the carbon dioxide (CO 2) burden of glass containers when shipping foods and beverages, according to a lifecycle analysis (LCA) published by the Glass Packaging Institute, Alexandria, VA.

Incorporating recycled glass (cullet) in the manufacturing process reduces the amount of energy needed to create molten glass for the production of new containers. The study conducted by PE Americas, Boston, MA, examines each step in the lifecycle of a glass container -- from raw material extraction to end-use -- and collected data from 105 furnaces representing 75% of North American glass container production. The glass container industry is working to reach a goal of 50% recycled content by the end of 2013. A few U.S. glass container manufacturing plants already achieve 70% recycled content. For more information, visit www.gpi.org/LCA.

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About the authorwww.Packexpo.com

Hallie Forcinio has covered packaging-related environmental topics for more than 20 years, first as an editor on Food & Drug Packaging magazine and more recently as a freelance packaging journalist. “My interest in the environment dates back to a high school government class,” she notes. “I was collecting glass, newspapers and aluminum cans for recycling long before my community had a curbside recycling program.”

In addition, to preparing the TricorBraun Sustainability Times, she contributes articles to numerous trade publications including Packaging Machinery Technology, Pharmaceutical Technology, Managing Automation and Ben Miyares’ Packaging Management Update, the weekly e-newsletter that posts each Monday on Packexpo.com.

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