The FTC’s revised Green Guides may impact furniture and bedding marketing/advertising

Posted by Kelsey Ness on November 12, 2012

Green Bed

Claims that a product helps the environment are enticing to consumers. In fact, the 2012 Green Home Furnishings Consumer Study found that people may be buying less but they are buying eco-friendly. Now the Federal Trade Commission (FTC) has issued a 314-page update to its Green Guides, which are intended to help eliminate confusion among consumers about “green” marketing claims by requiring marketers and advertisers to use clearer, more detailed language.

The Guides also help marketers avoid making sweeping claims without proof or qualification. With the furniture and bedding industry using an increasing amount of “green” materials – from recycled wood to soy-based polyols – it is essential that you understand how the finished products in your store’s inventory may now be marketed and advertised.

What are Green Guides?

First issued in 1992, the new Green Guides clarify and modify guidance on environmental claims, some of which have become increasingly more common since the last revisions such as carbon offsets, non-toxic claims, and claims that products are made from recyclable or renewable materials. While not enforceable by law, the FTC can take action under the FTC Act if a marketer makes an environmental claim inconsistent with these Green Guides.

Helping you to avoid over-stating the truth

In issuing these Green Guides, the FTC wants to help marketers avoid making sweeping, over-the-top claims that can’t be substantiated. For example, simply stating that a product is “eco-friendly” may be leaving too much up to consumers’ interpretation. The Guides further state that, “Marketers should not state or imply environmental benefits if the benefits are negligible” and clarify what information may be needed to substantiate a claim.

Say, for instance, that a manufacturer increases the recycled content of his product from two to three percent. He then states on his label: “contains 50% more recycled content than before”. While the claim is technically true, it likely gives the false impression that the manufacturer has significantly increased the use of recycled materials.

Some of the Green Guides that may apply to the furniture and bedding industries

• Recycled content: Do you carry reclaimed or recycled wood furniture? For products that contain used, reconditioned or re-manufactured components, the Green Guides state that, “Marketers should make recycled content claims only for materials that have been recovered or diverted from the waste stream during the manufacturing process or after consumer use.” If a product is only partially constructed of recycled content, “Marketers should qualify claims for products made partly from recycled material. For example, “Made from 30% recycled material”. The Green Guides further advise that, “Marketers whose products contain used, reconditioned or re-manufactured components should qualify their recycled content clearly and prominently to avoid deception about its components.”

• Recyclable content: Mattresses are recyclable, right? The recycling language used may depend on your location. A product should not be marketed as “recyclable” unless “it can be collected, separated or otherwise recovered from the waste stream through an established recycling program for reuse, or use in manufacturing or assembling another item.” When recycling facilities are available to at least 60 percent of consumers or communities where the item is sold, marketers can make unqualified recyclable claims. Otherwise, a marketer can state, “This product may not be recyclable in your area.” If recycling facilities for a product are available to only a few consumers, the FDA says a marketer should use stronger qualifying language: “This product is recyclable only in the few communities that have appropriate recycling programs.”

• Made with renewable materials: In its review process, the FTC discovered that consumers often misinterpreted this claim to mean that the product was recyclable, made with recycled content or biodegradable. To minimize the confusion, the Green Guides recommend that marketers “identify the material used clearly and prominently, and explain why it is renewable. For example, “Our flooring is made from 100% bamboo, which grows at the same rate, or faster, than we use it.” By identifying the material used and explaining why it is renewable, the marketer has minimized the risk of unintended claims. New BiOH technology allows our customers to create products with typical levels of renewable content at greater than 50 percent.

• Carbon offsets: It wasn’t all that long ago that the concept of a carbon footprint was foreign to most people. Now most everyone has a general idea of what it means. In its Green Guides, the FDA cautions that marketers should, “have competent and reliable scientific evidence to support carbon offset claims. They should use appropriate accounting methods to ensure they measure emission reductions properly and don’t sell them more than once.”

Preliminary life cycle analysis indicated that manufacturing BiOH polyols requires 60 percent less non-renewable energy and results in less global warming emissions than manufacturing the petroleum polyols we replace. Additionally, for every one million pounds of BiOH polyols used, more than 2200 barrels of crude oil are saved. Considering that the industry uses billions of pounds of petroleum polyols, BiOH polyols can have an impact on using less petroleum.

To view the complete Green Guides, information for business, and legal resources related to environmental marketing, go to A summary of the changes is available at


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  • GreenPeace said on December 13, 2012:

    There just has to be clarity across the Green gamet, or better education to the public. I work with and we see a huge misunderstanding (or clever marketing) promoting products to be green, organic, and fair trade all the time. Thanks for the post


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