Greenwashing Follow-up

By Ralph Velasquez, Guest Contributing Editor
Perspectives from the Green Boardroom
February 17, 2012

Well, I didn’t get any response on the December article regarding “greenwashing,” so I’m not sure if that is because it didn’t resonate with the audience or it hit too close to home.  Either way, I often do not exhibit common sense and know when to let something go, so throwing caution to the wind, I want to follow-up that article with the more recent study "The Seven Sins of Greenwashing™" by TerraChoice Environmental Marketing, whom I referenced in the first article.

In the last piece I referenced their 2007 study; this is their 2010 study.  I also thought I’d throw a bit more light on the FTC guidelines.

The newer 2010 TerraChoice study shows that within their same study parameters, “greener” products had increased 73%.  Of these, 95% violated one of the seven principles of greenwashing.  This was an improvement from the 2007 study.  To those with great memories and a keen eye, the 2007 study mentioned “six” sins, while the 2010 study mentions “seven” sins.

TerraChoice added: “The Sin of Worshiping False Labels is committed by a product that, through either words or images, gives the impression of third-party endorsement where no such endorsement actually exists," - fake labels, in other words.

While this is an improvement over 2007, there is obviously a lot of “sinning” going on out there.  More good news is that “sin-free” products have doubled each of the last two years.

Some of the other highlights included in the study identified that companies claiming BPA free products had increased 577%, while companies claiming Phthalate free products had increased 2,550%!  Wow, that’s a lot of “freeing” going on out there.  You’ll want to read the study closer if you have kids and buy toys or baby products.

I was particularly interested in the section on eco-labels.  Don’t know about you, but I see tons out there and believe the average consumer is totally confused.  The study did find that good eco-labels help reduce, but not eliminate, violation of greenwashing sins.  The good news is that based on ISO 14024, more than 30% were “sin-free” vs. the overall survey which only found 4.5% were “sin-free.”

That’s the good news; the bad news is that false eco-labels are increasing.  More than 32% of the products carried false labels.  TerraChoice reports that in some cases false labels can be purchased for just a few dollars.  They include a sample within their survey of one such label that they had purchased to illustrate their point.

For those of us who live in the building sector, there was better news.  TerraChoice reports that in the built environment there is an improved use of legitimate eco-labels.  They cite examples such as Energy Star, GreenGuard, UL Environmental and Ecologo.  Personally, I think the jury is still out on eco-labels, time will tell.

In my last piece, I referenced the FTC guidelines of reporting environmental claims and I thought I would expand a bit more on this.  The FTC Green Guides were first issued in 1992, revised in 1996 and 1998.  With increasing pressure from consumers and the business community alike, the FTC sought to update their guides and published some proposed revisions on October 6, 2010 for public comment.  The public comment closed on December 10, 2010.

In the 2011 FTC annual report, released April 1 of the same year, the FTC did not reveal when their proposed changes would become official.  We will have to wait for this year’s annual report to see if they address this issue or if some other public announcement will be made regarding these proposed changes.  If anyone out there has heard anything more, please let me know.

The FTC Green Guides do not have the force of the agency regulations, however; they describe what the FTC considers deceptive, thereby creating the de facto standards for green marketing.  The FTC has and will pursue companies for “deceptive” practices, so one needs to consider this when crafting your marketing position.  The FTC signaled their intent to take action nationally since beginning the review of the Green Guides in 2008.

In August 2009, for example, the agency sued four clothing manufacturers — Sami Designs and its subsidiaries and The M Group Inc. — to bar them from claiming their rayon garments were made from bamboo in an eco-friendly way and contained antimicrobial properties.  Six months later, the agency warned 78 retailers including Wal-Mart, Target and Kmart against selling similarly marketed products.

Also in 2009, the FTC sued Kmart Corp., Tender Corp., and Dyna-E International with making false claims that their paper products were "biodegradable."

Here are some of the key points in the proposed changes:

• General environmental benefits claims: Companies should not make unqualified general environmental benefit claims, such as “environmentally friendly” or “eco-friendly.”  This increasingly clear prohibition represents a shift from the existing Guides, which allow companies to make unqualified general environmental benefit claims as long as they can substantiate any express or implied claims.

• Certifications and seals of approval: The proposed revisions also require certifications and “seals of approval” to be objectively qualified where appropriate.  While companies generally should use independent third-party certification, use of their own certification process will not be deemed deceptive as long as they clearly and prominently disclose that they created the certification process and limit the representations that the product has environmental benefits to particular product attributes that the company can objectively substantiate.

• Degradability claims: Under the current Green Guides, a company marketing its product as “degradable” must be able to substantiate that the “entire product or package will completely break down and return to nature within a reasonably short period of time after customary disposal.”  The proposed revisions attempt to clarify this rule by stating that a “reasonably short period of time” cannot exceed one year after customary disposal.

• Made with renewable materials/renewable energy: The proposed revisions offer guidance related to marketing products that are made with renewable materials and/or manufactured using renewable energy.  Companies should qualify claims that their products are made with renewable material by explaining what renewable material is contained in the product, how it is sourced, and what makes it renewable.  Moreover, if the products contain both renewable and non-renewable materials, the company should qualify the scope of renewable materials that are used in the product.

• Carbon offsets: Under the proposed revisions, companies that sell carbon offsets (a type of credit or certificate that can be purchased to neutralize one’s “carbon footprint” by funding projects that reduce greenhouse gas emissions) must have competent and reliable scientific evidence to support their carbon offset claims in order to advertise that they participate in such programs.

So, while we await the further FTC rulings, we are carefully monitoring the evolution of eco-labels, looking forward to the next TerraChoice survey, and internally making sure we do the best job we can to be in line with best practice principles when marketing our green solutions.  I think the Construction Specifications Institute (CSI) directive of being “clear, correct, complete and concise” could also apply to our thinking when making marketing claims.

With the advent of social media, being transparent is the order of the day and a prudent course of action.  Of course, one would hope that transparency would be the order of the day because it is the right thing to do and not just because it is the legal minimum or that we might be caught in the social media “fishing net” and exposed.

So let’s end these two articles with this thought:

Do what’s right when no one is looking, as if everyone is and you will be just fine…..don’t you love grandma’s wisdom!


The Green Lantern…..aka….Ralph Velasquez

Ralph Velasquez
Executive Director of Sustainability
Tremco, Inc.

Contact Ralph at: phone (VM) 877.510.2681 or

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