Some advice from the FTC’s “Complying with the Environmental Marketing Guides.”
General claims > Specific environmental claims are easier to substantiate than general claims, and less likely to be deceptive. An unqualified general claim of environmental benefits may convey a misleading impression that the product has far-reaching environmental benefits.
Eco-Seals, seals-of-approval and certifications > Environmental seals-of-approval, eco-seals and certifications from third-party organizations imply that a product is environmentally superior to other products. Because such broad claims are difficult to substantiate, seals-of-approval should be accompanied by information that explains the basis for the award. If the seal-of-approval implies that a third party has certified the product, the certifying party must be truly independent from the product manufacturer and must have professional expertise in the area that is being certified.
Degradable, biodegradable or photodegradable claims > Claims that a product is “degradable,” “biodegradable” or “photodegradable” mean that the materials will break down and return to nature within a reasonably short time after customary disposal. The length of a “reasonably short time” depends on where the product is disposed.
“Recyclable” claims > “Recyclable” claims on labels and advertisements mean that the products can be collected, separated or recovered from the solid waste stream and used again, or reused in the manufacture or assembly of another package or product through an established recycling program. A claim of recyclability should make clear to consumers whether it refers to the product, the package, or both.
“Please Recycle” claims > Consumers interpret the phrase “Please Recycle” on products or packages to mean that the product or package is recyclable. That’s why the same guidelines for making “recyclable” claims apply to “Please Recycle” claims. Unless recycling collection sites for the product are available to a substantial majority of consumers or communities where the product is sold, the “Please Recycle” phrase should not be used unless it is qualified.
“Recycled Content” claims > “Recycled content” claims on labels and in advertising may be made for materials that have been recovered or diverted from the solid waste stream, either during the manufacturing process (pre-consumer) or after consumer use (post-consumer). If the product or package does not consist of 100 percent recycled content (excluding minor, incidental components), qualifying words—like the percentage of recycled content in the product—must be used to limit the claim.